Courtney and Brenda Lundquist - Page 18




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          years at the time of trial.  In 1997, he bred about 75 to 80                
          mares.  He had three stallions.  About 25 percent of his business           
          was breeding, including about 10 percent of which was selling               
          foals.  His gross receipts in 1997 were about $200,000, of which            
          about 25 percent was from breeding.  The 5 to 10 breedings per              
          year which petitioner wrote on the back of her letter to Dixon              
          are considerably fewer than Emerson's 75 to 80.                             
               Petitioner's letter to Dixon does not show that petitioner             
          in 1985 had a bona fide objective that her horse activity would             
          become profitable.                                                          
               Petitioners contend that petitioner's business plan was to             
          import dressage horses from Europe and breed and sell them in the           
          United States.  Petitioner thought Temptation, Labrette, and the            
          stallion Zenit could earn a profit because Planzor had told her             
          that she could earn $15,000 per foal.  This was a dubious                   
          assumption for her to make because she bought brood mares in                
          Europe for $1,500 to $3,500.                                                
                    c.     Financial Records                                          
               Petitioner kept invoices, receipts, canceled checks (and a             
          spreadsheet summarizing them), and bank statements, which she               
          gave to the accountant to prepare petitioners' annual returns.              
          However, petitioner did not have budgets, balance sheets, income            
          projections, or other financial statements for her horse                    
          activity.  There is no evidence that she used her records to help           
          her evaluate or improve the financial performance of her horse              
          activity.                                                                   


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