- 21 - years in issue.2 Petitioner's limited advertisements do little to show that she conducted her activity in a businesslike manner. g. Emerson Emerson testified that petitioner operated her activity in a businesslike manner. We disagree. Emerson first met petitioner in 1993 or 1994. He did not know how much she earned from stud and boarding fees or the sale of foals. He never saw business records or a business plan for petitioner. Emerson was a member of the U.S. Equestrian Team that competed in the 1974 world championships and the 1976 Olympics. He was national 3-day champion in 1976 and 1979. Emerson attributes his financial success to his personal fame. Petitioner lacked this advantage. Emerson received gross receipts of about $50,000 from breeding 3 stallions and 75 to 80 mares. The rest of his income was from clinics and training. Petitioner had one lame stallion and a few mares. She had no income from training or clinics. Emerson's conclusion that breeding Temptation could have been profitable is not enough to show that petitioner had an actual and honest profit objective. This factor favors respondent. 2 Petitioners deducted advertising expenses of $878 for 1988, $628 for 1989, and $632 for 1990. The record includes no information about these expenses. In 1991, petitioner advertised that Labrette was for sale.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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