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and evidence that Mrs. Sullivan supplied the latter service, we
believe on balance that the transaction involving Miss Doc Chic
demonstrates that Mrs. Sullivan's actual participation in cutting
horse competition, which undeniably has a substantial
recreational component, was an important priority in petitioners'
horse-related activities.
Second, although it is petitioners' contention that a key
component of a cutting horse stallion's value is the demonstrated
performance of his offspring, at trial they were uncertain of the
number of offspring sired by their current prize stallion
(Colonel Rey Lew) and were familiar with the performance of only
seven or eight such offspring, whereas there were 22 documented
breedings of that stallion. Thus we do not believe petitioners
were documenting the value of their stallion in a businesslike
manner.
Petitioners also argue that their use of stallions, rather
than geldings or mares, in cutting horse competitions indicates
that they conducted their activities as a business rather than a
hobby. According to petitioners and other knowledgeable
witnesses, stallions are less tractable and more temperamental
than geldings or mares, and thus using stallions in cutting horse
competitions is much more difficult. A hobby enthusiast would
utilize a gelding or mare in cutting horse competitions, it is
argued; only a business-oriented participant, interested in the
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