Jack F. and Virginia Surridge - Page 4

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          In 1991, petitioners bred two of their broodmares, "Kamla" and              
          "Meczewza", with stallions owned by other breeders.                         
               Petitioners are members of various Arabian horse                       
          associations, registries, and clubs.  They subscribe to various             
          magazines and newsletters, and they attend various classes and              
          seminars pertaining to horse raising and care.                              
               Petitioners have never used in vitro fertilization                     
          techniques as part of their horse breeding activities, and they             
          have never commissioned a study of Arabian horses' bloodlines to            
          determine those horses that are most likely to sire foals of                
          racing potential.  They do not maintain a bank account for their            
          activity separate from their personal accounts, and they do not             
          maintain journals, ledgers, or organized records of income and              
          expenses for their activity.  They have never prepared income               
          statements, balance sheets, income projections, or any other                
          financial guidelines for their activity.  They have never                   
          reported a profit from their activity, or from any other                    
          horse-related activity, on any Federal income tax return.                   
               During the years in issue, petitioners collected insurance             
          proceeds totaling $15,000 for injuries or death suffered by their           
          horses, and they had life insurance policies on many of their               
          horses.  In 1993, they sold one horse for $1,500.                           
               With respect to the subject years, petitioners reported on             
          their joint tax returns the following amounts of pension income,            
          self-employment income, capital gain income, farm income (loss),            



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