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records to determine what, if any, income and expenses they had
in connection with their horse activity.
Petitioners also maintained records on the breeding of each
of their horses. Beginning in 1982, petitioners bred the horses
they purchased. Later, during 1991 and 1992, petitioners bred
their mares Traders K, Angular Pleasure, Bad Memories, and Its
Legit to the stallion Tagish for a stud fee of $2,000 each.
During 1993, petitioners bred their mares Its Legit and Angular
Pleasure to the stallion Deerhound for a stud fee of $2,500 each.
Angular Pleasure was again bred to Deerhound in 1994 for a stud
fee of $3,000. Finally, petitioners bred their mares Traders K
and Tekla Tekla Two to the stallion Norquestor for a stud fee of
$3,500 each.
As a result of petitioners’ having bred their mares to the
above-mentioned stallions, a number of foals have been produced.
By breeding their mares to Norquestor, petitioners had produced,
at the time of trial, one horse of racing age and two yearlings.
Petitioners estimate an average value of $15,000 for each of
their foals bred from Norquestor.
The property upon which petitioners maintained their horse
operations and their horses was not open to the public.
Petitioners did not ride the horses themselves nor allow others,
except for professional trainers, to ride their horses.
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