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would typically receive the booking fee in one year and the stud
fee in the next.
During the year at issue, in addition to the quarter horses,
petitioners owned seven horses: Ding Dong Daddy and Halyard,
three mares, and two yearlings. Petitioners also boarded four
additional horses during 1993.5 According to a chart submitted
at trial, petitioners would charge $7 a day for boarding or $7.50
per day if the horse had a foal at her side. These fees included
feed. The cost of feed per month per horse is about $100.
Petitioners would add veterinarian and trimming fees to the bill.
Of the four boarded horses, two were bred for which petitioners
charged a $100 breeding fee. Another horse had a foal at her
side; it had been bred at Midget Acres in 1992, but the stud fee
had not yet been collected.
Petitioners sold two of their horses, Jenny Sport and Actis
Uptis, in October of 1993 for $1,000 each. (It is not clear
whether these horses were included in the seven referred to
above.) Jenny Sport was a racing horse that was a gift to
petitioner after it broke down at the track, and Actis Uptis,
sired by Ding Dong Daddy, was born at Midget Acres. Petitioners
did not have a cost basis for either horse.
Petitioners billed a total of $4,297 in 1993. However, they
collected only $2,892, including the $2,000 for the sales of the
5 With only four stalls and four pipe pens, petitioners had
room for only eight horses. When they had the additional
boarders, petitioners sent their own horses to the neighbor’s
pen.
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