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and wife, and they filed joint Federal income tax returns for all
years in issue. They resided in Maple Valley, Washington, when
they petitioned the Court. Ms. Surridge is a full-time insurance
agent who works as a sole proprietor. Mr. Surridge is a retired,
career serviceman who is involved full-time on the family farm.
Ms. Surridge purchased her first horse in 1959 or 1960. She
began raising Arabian horses approximately 10 years later with
the intent to show them. She abandoned this intent
by the early 1970's, opting to breed and raise Arabian horses
with an intent to race them. She raced two Arabian horses in or
about 1974, and she did not race any more horses until
approximately 1984. Mr. Surridge began participating in Ms.
Surridge's horse-related activities in 1976. Neither he nor she
is a State certified or licensed horse trainer.
From 1990 through 1994, petitioners maintained a stable of
approximately 25 horses, four of which were capable of racing.
The remaining horses were broodmares, stallions, geldings, and
horses too young or physically unable to race. During the
subject years, the number of races in which the four horses
participated, and the amount of prize money that each horse won,
are as follows:
Horse Number of Races Prize Money Awarded
Bey El Shaw 4 $100
Sir Latigo 6 500
Parkwood Barbaado 15 2,237
Mystic Moods 6 uncertain
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