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not engaged in for profit. We agree with respondent.
Petitioner, who from early childhood was involved with horses,
decided that her ability to practice law was diminishing and that
it was necessary to find some other source of income. Because
she was beginning to experience memory loss, petitioner decided
that the horse-related activity would be more apropos. Beginning
about 1986, she investigated the potential to earn income from
horse-related activity. Petitioner visited horse farms, read
magazines and reference materials, and consulted farriers
concerning the operation of horse activities. After completing
her research, in 1989 petitioner commenced her horse activity.
Based on her research, she set the goal of acquiring a
champion stallion for the purpose of selling its stud services.
Her goal was to be accomplished by either purchasing or breeding
champion stallions. After acquiring stallions, they were to be
shown and publicized to build a high quality reputation. She
projected that once the stallion attained some recognition, the
stud service fees would provide a stream of income. She stated
that a champion stallion could produce from $100,000 to $300,000
in stud fees and that merely showing horses would not provide
sufficient income to recoup the costs of acquiring, maintaining,
showing, and training horses. Petitioner chose a particular type
and breed of horse and sought out a particular bloodline for
acquisition. Petitioner, who possessed a considerable background
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