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initial string of losses may qualify as a "startup" period, which
suggests that later periods of losses may not so qualify.
After two profitable years in 1981 and 1982, petitioners
realized losses in every year from 1983 through 1995.
Petitioners' efforts to account for this period center on the
careers of two prize stallions, Docs Fancy Feat and Colonel Rey
Lew.
Petitioners attempt to account for roughly the first half of
these losses by citing a series of mishaps and bad luck they
encountered with Docs Fancy Feat. Docs Fancy Feat was born in
1976 and was from respected bloodlines. He showed great promise
as a 3-year-old, missing by a fraction of a point the finals of
the Futurity competition for 3-year-olds in 1979, while being
ridden by Mr. Hightower. Nevertheless Docs Fancy Feat never
realized his true potential to become quite valuable, according
to petitioners, because of a series of problems. First, Mrs.
Sullivan became pregnant in 1981 and did not ride Docs Fancy Feat
in competition in that year or 1982. Due to Mrs. Sullivan's
condition, Docs Fancy Feat was sent in August 1981 to a trainer
in Arizona, who wished to ride him in competition. However, Docs
Fancy Feat suffered colic from the trainer's feeding practices
10(...continued)
purchased in 1969 was injured and had to be euthanized, and a
superior mare suffered a nonfatal injury and had difficulties
delivering a live foal in the mid-1970's.
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