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however, it became clear to petitioners that the lessor had plans
to develop the property.
Mr. Hudnall worked full time as an interstate truck driver
while in Tennessee and continued to do so after the family's move
to Maryland. Mr. Hudnall was away from his family most of the
year at issue and did not actively participate on the farm. He
reported wages of $38,721 from his truck driving in 1993.
Petitioners' stated intent in moving to Maryland was to
launch Victoria Stables, a horse-boarding venture to have been
managed by Mrs. Hudnall. Mrs. Hudnall had no formal training for
horse boarding but asserts that she grew up around and had
knowledge of horses because of her father, a longtime horse hand.
Petitioners do not account for any business preparation
other than selecting and renovating the farm. Petitioners do not
claim that they advertised the business or had any detailed plans
on how to conduct the business. All work on the farm, primarily
cleaning stables, was done by Mrs. Hudnall or by family members
lending a helping hand.
According to petitioners, their clientele consisted of a
polo team, a short-term visitor from Brazil, and an independent
horse trainer. Petitioners claim that their clients handled the
daily maintenance of their horses. Petitioners produced neither
receipts nor averments from any of the clients. Any other
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