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Petitioner went to England, France, and Germany in 1977 on a
tour of breeding farms, race tracks, and training centers
sponsored by Cornell University. Petitioner also toured similar
facilities in Ireland on a date not specified in the record. He
took courses about horses at Cornell University in 1985, 1986,
and 1990, and stud manager’s courses in 1964 and 1970.
From 1961 to 1996, petitioner gave away 124 horses that were
not performing well because it cost too much to maintain them.
5. Records and Reports
Westfield Gage (not petitioner) paid Kuta to keep the
records for petitioner's horse racing and breeding activity from
1955 through the years at issue. She spent 10 to 15 percent of
her time working on the horse racing and breeding activity. Some
of that time was at the end of each year when she gathered
information for petitioner's tax returns. Kuta decided which
records of the horse racing and breeding activity to keep and how
to keep them.
Petitioner had a separate bank account for his horse racing
and breeding activity from 1963 through the years in issue. Kuta
kept copies of canceled checks, check registers, invoices, and
correspondence that related to the horse racing and breeding
activity.
At the end of each year, Kuta prepared summaries from race
track statements to ensure that the Forms 1099 issued by the
racetracks were accurate. She also used race track statements to
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