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competitions. Petitioners did not receive any cash or property
with respect to this arrangement.
Petitioners purchased Ben Hur, a stallion, in 1992 for
$12,000. Morgan stallions generally begin to breed at about 4
years of age and can breed until approximately 28 years of age.
Ben Hur has not produced offspring since petitioners purchased
him, although he did produce offspring prior to their ownership.
Petitioners claimed Ben Hur as part of their show horse activity
in 1992, 1993, 1994, 1995, and 1996. Ben Hur participated in the
following horse shows:
Name or Prize money
location Years earned Expenses
Gold Cup 1992/1994/1995 Unknown $862
River Ridge 1992/1994/1995 Unknown 792
Twin Rivers 1995 $35 525
Buckeye 1992/1994/1995 75 615
Ohio State Fair1994 Unknown 266
KYOVA 1994 Unknown Unknown
Blue Ribbon Classic 1994/1995 Unknown 350
Delaware Cty Fair1994 Unknown 182
Penn-Ohio 1992 15 408
Totals 125 4,000
Petitioners purchased Chicardo, a 3-year-old stallion, in
1985 for $1,500. Petitioners gelded Chicardo in 1991 or 1992
because they decided that he was not good enough to hold for
breeding. Petitioners claimed Chicardo as part of their show
horse activity for 1994 and 1995. Chicardo did not participate
in horse shows after 1990. Chicardo was ridden partly for
pleasure because he was not as valuable as Ben Hur or
Riskybiznis, and petitioners were planning to sell him as an
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