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did not use any real estate owned by them in their horse breeding
or horse racing activities in any of the tax years 1976 through
1996. Except for horses which are racing, in training to race, or
boarded at a stud ranch, all of petitioners' horses are boarded at
Rancho del Charro, a commercial horseboarding facility located
approximately 30 miles southeast of petitioners' residence. Elvin
Adams (Adams) is the ranch manager of Rancho del Charro.
The horses which are racing are trained and boarded at the
racetrack. There are two major racetracks near petitioners' home.
One of the tracks is approximately 10 miles northwest of
petitioners' residence, and the other is about 35 miles southwest
of petitioners' residence. The racetracks do not operate at the
same time of year. Jeff Bonde (Bonde) trains petitioners' horses at
the racetracks.
Several of petitioners' horses have won more than $100,000
over their racing careers. Petitioners have also been "breeding up"
their horses for higher stakes races by upgrading their brood mares
and the stallions with which they are bred. Petitioners currently
have two horses entered in Breeder's Cup races which have purses
over $1 million.
Several horses have had their racing careers, and; in some
instances their lives, ended by unforeseen and unfortunate
circumstances which were beyond petitioners' control. Petitioners'
horses, Super High Pockets1, Miss Super Natural, Glorious and Bold,
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Last modified: May 25, 2011