Courtney and Brenda Lundquist - Page 3




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               Petitioner loves animals.  From 1966 to 1984, petitioner               
          bred English sheepdogs, Yorkshire terriers, and Maltese terriers.           
          She sold 10 to 15 puppies.  Petitioner did not report any income            
          from this activity on her tax returns for tax years 1978 to 1984.           
               Petitioner is not a horse trainer and does not have any                
          formal training in horse breeding.  However, she has been                   
          interested in horses since she was 9 or 10 years old.  She rode             
          horses when she was a child.                                                
          B.   Dressage Competition                                                   
               Dressage is an Olympic sport which involves training a horse           
          to do basic movements that are executed in a small arena in front           
          of a panel of judges.  A dressage program is analogous to                   
          compulsory movements in figure skating.  Three-day eventing is              
          also an Olympic sport.  It consists of a day each of dressage,              
          cross country, and stadium jumping.                                         
               A dressage horse can start training when it is 3 years old.            
          A horse can compete in medium level competitions when it is 6 or            
          7 and in upper level competitions when it is 8 or 9.  Dressage              
          levels are training, first, second, third, fourth, fifth, Prix              
          St. Georges, Intermediare I, Intermediare II, and Grand Prix.               
               Dressage competitions award ribbons and prizes such as coats           
          and coolers but do not offer monetary prizes.  Traditional                  
          dressage horses are called "warmbloods", which are a mixture of             
          European horse breeds and thoroughbreds.  The main warmblood                
          breeding centers were in Europe in 1982.                                    




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