Donald Keith Morley and Rebecca B. Morley - Page 6

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               Mr. Morley attended horse shows to learn about the horse-              
          breeding business.  He also showed his horses at these events and           
          won several ribbons.  After initially hiring a local trainer, Mr.           
          Morley hired a professional trainer to show and care for his                
          horses.  Additionally, Mr. Morley maintained a booth at the horse           
          shows displaying the farm logo, the promotional materials, and              
          ribbons that the horses had won.                                            
               Mr. Morley made "notices" with information on each of his              
          horses.  These notices contained the name, registration number,             
          breed, color, sex, and price of the horses for sale.  The notices           
          also contained information on who the horse was "in foal to"                
          (i.e., to whom the horse was bred and when the foal was due).               
               Mr. Morley advertised the horse-breeding activity in various           
          equine periodicals.  He provided notices and narratives about his           
          horses to potential purchasers.  He also prepared, for                      
          prospective customers, a document containing a cost analysis of             
          raising a horse.                                                            
               All year round, Mr. Morley worked 4 days a week at his                 
          dental practice and 7 days a week on the farm.  During the fall,            
          winter, and spring, he spent 40 hours a week at his dental                  
          practice and 10 to 20 hours on the horse-breeding activity.  In             
          the summer, Mr. Morley worked 40 hours on the farm and 32 hours             
          at his dental practice.                                                     
               Mr. Morley personally handled many horse-breeding activity             
          duties.  He fenced the farm, repaired equipment, cleaned the                



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