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horse activity. It was Mr. Haun who during relevant periods
performed virtually all of the tasks relating to the roping horse
activity. During the years at issue, he was able to, and did,
spend time in that activity only on the weekends and before and
after his full-time work at BellSouth during the week. Part of
the time on the weekends that Mr. Haun spent during the years at
issue in the roping horse activity was recreational.
In July 1991, petitioners began construction on the Haughton
property of an arena for training roping horses (roping arena).
That arena was completed in September 1991 and has been used by
Mr. Haun since that time for training roping horses. Since it
was constructed in 1991 through to the date of the trial in this
case, the roping arena did not have any bleachers or lights and
was not suitable for staging events for either roping horse
competitions or roping horse practice sessions. At no time prior
to, during, or after the years at issue to the trial date herein
did petitioners hire anyone to assist them in the roping horse
activity. Petitioners could have held roping horse competitions
in the roping arena since it was completed in September 1991 for
which entry fees could have been charged if they had added
lights, leased or purchased cattle, and hired some help. They
also could have held roping horse practice sessions in the roping
arena since that time for which entry fees could have been
charged without hiring anyone if they had added lights and leased
or purchased cattle. Although at some time not disclosed by the
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