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junior high school. Throughout his life, Mr. Haun has enjoyed
using horses for, inter alia, roping, including team roping,
trail riding, and hog hunting and has participated in various
recreational activities involving roping horses, including
attending roping horse shows, races, and competitions. Mr.
Haun's participation in those recreational activities was reduced
somewhat after petitioners started training and selling roping
horses (roping horse activity) on the Haughton property some time
during 1991.
Before petitioners started the roping horse activity in
1991, Mr. Haun consulted with Robert Cook, a lawyer, who advised
him to incorporate that activity because of liability concerns.
That lawyer referred petitioner to Charles D. Churchill, a
certified public accountant, who prepared petitioners' return for
1991.
Sometime prior to the years at issue, Mr. Haun also con-
sulted with Robert Rich, Jr., a professional horse trainer, about
the demand for and the difficulty of finding good horses and with
another professional horse trainer, Ben Lolly (Mr. Lolly), about
the amounts for which horses with which Mr. Lolly was familiar
were bought and sold. Mr. Lolly told Mr. Haun about certain team
roping sales that had just started and about the United States
Team Roping Championships (USTRC). Two people are needed in team
roping, a header and a heeler. The header ropes the horns of the
cattle, and the heeler ropes its back feet. As of the time of
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