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record petitioners had purchased lights and made arrangements to
purchase cattle, both of which were needed to hold roping horse
competitions and practice sessions, as of the trial date in this
case those lights had not been installed in the roping arena,
petitioners had not purchased those cattle, and petitioners had
not held any roping horse competitions or practice sessions in
the roping arena.
In addition to constructing the roping arena in 1991, Mr.
Haun's involvement in the roping horse activity during relevant
periods included constructing a barn with four stalls, a horse
walker, paddocks, and a pipe fence. Since 1991, Mr. Haun has
regularly cleaned the horse stalls, fed, watered, blanketed,
shoed, wormed, and performed other uncomplicated veterinary
procedures for the horses (e.g., vaccinating them), trained them
to be roping horses, which takes about two years, rode the roping
horses in competitions, and used a tractor in the roping arena.
Prior to 1993, petitioners formed Rafter H, Inc. (Rafter H)
and have been its sole shareholders since that time. On January
1, 1995, petitioners transferred all the interests that they had
in the roping horse activity, including the horses that they
owned, to their wholly owned corporation Rafter H in exchange for
additional voting common stock in that corporation, but they did
not transfer any of their interests in the Haughton property to
Rafter H.
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