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nonprofessional class weekend competitions in 1994 and likewise
qualified for the nonprofessional finals of the World
Championship. Petitioners consider Colonel Rey Lew to be a very
promising stallion. At the time of trial, they estimated his
value to be between $100,000 and $150,000. Including Colonel Rey
Lew, the total value estimated by petitioners for the eight
horses they owned at the time of trial was between $170,000 and
$222,500.
Petitioners sold two horses between 1989 and 1990, which
failed to show promise as cutting horses, for $3,500 and $4,000,
respectively. Petitioners did not sell any horses during 1992.
Of the six horses they owned in 1992, one was sold in 1993 for
$6,500 and another in 1995 for $3,500. There is no evidence
concerning the sale of any other horses that petitioners owned
between 1989 and 1995, except Miss Doc Chic, purchased by
petitioners for $100 in 1992 and sold back to the seller by them
approximately 18 months later for $100. During the period they
owned Miss Doc Chic, petitioners treated the expenses of her
upkeep and costs associated with her entry in cutting horse
competitions as part of their horse-related activities. Mrs.
Sullivan rode Miss Doc Chic in nonprofessional class
competitions3 during 1992 when Mr. Hightower was riding Colonel
3 In order to qualify for nonprofessional competition, the
horse must be ridden by an owner who is not a professional
(continued...)
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