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hired some help. They also could have held roping horse practice
sessions in that 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 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, and petitioners had not purchased those cattle,
hired anyone to assist them, or held any roping horse competi-
tions or practice sessions in the roping arena.
Although during and after the years at issue Mr. Haun
performed virtually all of the tasks relating to the roping horse
activity, 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. We find the nature of the tasks and
the amount of time that Mr. Haun spent in the roping horse
activity during and after the years at issue to be consistent
with his lifetime enjoyment of horses.
Petitioners had sufficient income during the years at
issue,4 notwithstanding the losses from the roping horse activity
4 Petitioners reported the following amounts of wage income
(continued...)
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