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to drag manure, checked the fences, checked horse manure for
sand, and cleaned the stalls.
Petitioner used a Corvette as the vehicle for her horse
activity to haul hay, halters, and feed ropes. She drove it to
all the competitions.
Petitioner never competed in any equestrian events.
However, she attended those in which her horses competed.
6. Finances and Records
Petitioner did not have a separate checking account for her
horse breeding activity in 1988, 1989, or 1990. Petitioner
segregated from her personal records those which related to the
horse activity and rent receipts and checks. She also had a
credit card which she used only for her horse activity.
Petitioner summarized the checks for her horse activity in
spreadsheets listing the check number, amount, date, payee, and
general category of expense such as feed and hay, veterinarian,
tack and supplies, dues and fees, labor, horse transportation,
horse board, and office supplies. Petitioner gave her
spreadsheets, check stubs, and credit card and cash receipts to
her accountant during the years in issue.
7. Petitioner's Lack of Sales
Petitioner was surprised that buyers were not interested in
the warmblood horses that she had for sale in the years in issue.
She concluded that her potential customers were interested in
color and marking but not pedigree.
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