Dana L. McNaught - Page 4




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          was able to sell several of the foals, one to a person from New             
          York.                                                                       
               In 1981, petitioner decided to expand her horse breeding               
          activity from a hobby to a business and began claiming tax                  
          deductions for her expenses.  This decision was a result of                 
          conversations that she had with prominent members of the National           
          Appaloosa Horse Club, which acts as the official registry for               
          Appaloosas.  Petitioner thereafter began breeding more than one             
          broodmare simultaneously.  She also became very active in the               
          Appaloosa Horse Club of Oregon.  She has served as its secretary            
          and has organized and served as a judge at Appaloosa shows.                 
               Petitioner has become knowledgeable in the different                   
          pedigrees and breeding lines of Appaloosas by consulting with               
          other individuals in the business of breeding and training                  
          Appaloosas.  Her business plan focuses on breeding Appaloosas in            
          the $5,000 to $15,000 price range for sale to young riders and              
          nonprofessional adult riders.  Petitioner believes that her                 
          target market is broader than the market for horses in the                  
          $30,000 to $50,000 price range and will allow her to make a                 
          profit by reason of a greater number of sales.  At the same time,           
          she believes that her target market is more profitable than the             
          market for less expensive horses because the profit margin for              
          lower quality horses is minimal.  She therefore seeks to breed              
          Appaloosas with quiet dispositions that are easily trained and              
          are suitable for the amateur riders in her target market.                   




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