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During the years 1980 through 1995, Mr. Taras owned and
operated a framing and truss fabrication business in Walnutport,
Pennsylvania. As a framing contractor, Mr. Taras employed and
supervised as many as 5 to 10 employees whose primary function
was to frame houses and fabricate trusses. On Schedule C, Profit
or (Loss) From Business or Profession, petitioners reported net
income of $33,283, $32,261, $25,517, and $38,926 from the framing
and truss fabrication business for 1987, 1988, 1989, and 1990,
respectively.
Mr. Taras grew up on his family’s farm. During those years,
the family farm had horses as did other farms on which Mr. Taras
worked when he was a teenager. In 1980, petitioners lived on a
1-acre parcel of land that is adjacent to a 2-acre parcel owned
by Mr. Taras’ parents. Petitioners kept their horses on the 2-
acre parcel during the years at issue.
Prior to 1980, petitioners made plans to begin racing and
breeding horses. Petitioners did not have any experience in
racing or breeding horses. Petitioners' plan generally consisted
of a desire to purchase racehorses, race those horses, and
thereafter to breed their horses in an effort to eventually race
the horses they bred. In the summer of 1979, petitioners
contacted Ms. Audrey Kraynik, who represented that she was the
only female licensed horse trainer in Pennsylvania and that she
had trained horses for a number of years. Petitioners did not
consult with anyone other than Ms. Kraynik and her two personal
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