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roping sales that had just started, and the USTRC. However,
there is nothing in the record establishing that the individuals
to whom Mr. Haun spoke prior to the years at issue had discus-
sions with, or made any recommendations to, petitioners with
respect to making the roping horse activity profitable or that
petitioners accepted any such recommendations that they might
have made. In this connection, petitioners did not call as
witnesses any of the individuals to whom Mr. Haun spoke prior to
the years at issue. We presume that they did not call them as
witnesses because their testimony would have been unfavorable to
petitioners' position in this case. Wichita Terminal Elevator
Co. v. Commissioner, 6 T.C. 1158, 1165 (1946), affd. 162 F.2d 513
(10th Cir. 1947).
Nor have petitioners shown that they changed the operation
of the roping horse activity during or after the years at issue
in order to generate a profit or that they hired any individual
with the expertise and experience necessary to make that activity
profitable. In fact, since the roping arena was constructed by
Mr. Haun in 1991 through to the date of the trial in this case,
that 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. 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
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