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The sole issue for decision is whether petitioner operated
her horse breeding activity for profit in 1988, 1989, and 1990.
We hold that she did not.
References to petitioner are to Brenda Lundquist. Section
references are to the Internal Revenue Code.
I. FINDINGS OF FACT
A. Petitioners
Petitioners are married and lived in Lake Worth, Florida,
when they filed their petition. They have no children.
Petitioner Courtney Lundquist (Mr. Lundquist) owned
Winnipesocki Airlines, a commuter airline, until he sold it in
1979. He later became a pilot for Delta Airlines. He retired
from Delta in 1989.
Petitioner graduated from high school in 1959. She
graduated from Bay State Junior College with an associate's
degree in business in 1961. She worked as a flight attendant for
Northeast Airlines for 2 years. She then worked for Avis Rent-a-
Car, first as a rental agent and later as Avis' director of
training at Logan Airport.
In 1966, petitioner began working for Kelly Services, Inc.
(Kelly), as a branch manager. She became an area sales manager
and helped Kelly obtain contracts including Ray-Chem and a
regional Nielsen television survey. In 1976, petitioner began to
work for Winnipesocki Airlines. She was president when her
husband sold it in 1979.
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