Joyce E. Hastings - Page 14




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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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