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C. Early Years of Petitioner's Horse Activity
In 1976, petitioner began her horse activity when she bought
two young Anglo-Arab horses and began to learn about horse
breeds. She investigated dressage competitions, European horses,
and breeding and concluded that warmblood horses from Europe are
better for dressage than American thoroughbred horses.
Petitioners first reported on their tax return that petitioner's
activity was a business in 1979.
Sometime during the early years of petitioner's horse
activity (on a date not stated in the record), a horse threw her,
causing her to have a concussion and temporary loss of sight.
She has not ridden since then.
Horst Planzor (Planzor) owned Westfalian Pride Farm in
Poolesville, Maryland. In 1980 or 1981, petitioner visited
Planzor three times at his farm, where she saw his horses.
Planzor was a past president of the American Hanoverian Society.
Planzor owned a Hanoverian breeding stallion.
D. Petitioner's Purchase of European Horses and First
Competition
1. Petitioner's First Trip to Europe To Buy Horses
Petitioner went to Germany in February 1982 with Michael
Poulin (Poulin) and Ruth Sarkunas (Sarkunas). Petitioner
intended to buy two brood mares and a horse to perform in shows
and compete. Poulin was a dressage trainer from Maine and a
member of the U.S. Olympic team. Sarkunas was one of Poulin's
students. Sarkunas had trained with Nuno Olivera, who was well
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