Courtney and Brenda Lundquist - Page 2




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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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