James L. Sullivan and Dorothy B. Sullivan - Page 3

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               Since 1969, petitioners have owned as many as 20 horses and            
          as few as five.  In 1992, they owned six horses, including two              
          stallions.  Petitioners initially boarded their horses but in               
          1976 purchased a 17-acre tract on which they built a residence              
          and have since kept most of their horses.  The property includes            
          a barn that can accommodate six horses, other equine facilities,            
          and 10 acres of pasture.                                                    
               Petitioners' horse-related activities were conducted                   
          predominantly by Mrs. Sullivan during 1992.  Mr. Sullivan worked            
          80 to 100 hours per week in his business, Sullivan Money                    
          Management, Inc., during the year and does not ride or show                 
          horses.  During 1992, Mrs. Sullivan devoted 6 to 7 hours per day            
          on weekdays to their horse-related activities and a like amount             
          of time on weekends when she participated in horse shows.  At the           
          time of trial, Mrs. Sullivan rode in nonprofessional and novice             
          class shows.  Mrs. Sullivan provided most of the manual labor               
          required in caring for their horses, such as cleaning stables,              
          without the assistance of hired labor.  Petitioners paid third              
          parties for veterinary, training, and farrier services and, in              
          1992, they paid a professional trainer to show one of their                 
          stallions in competition.  Petitioners have never trained other             
          people's horses as part of their horse-related activities.                  
               Mrs. Sullivan has had a longstanding interest in horses,               
          from the time she was 14.  She participated in rodeo and hunter-            





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