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seed and hay. In 1988, they changed their operation to one
involving horses. On September 18, 1991, petitioner purchased
Coughlin’s interest in the Arkansas ranch for $12,905 and,
subsequently, changed the name of the ranch to the “Dean Sanders
Ranch”. Also during 1991, petitioner and Coughlin sold the last
horses that they jointly owned. During 1992 and 1993, petitioner
bought yearling horses, trained them, took them to various horse
shows, and sold them. Petitioner had begun purchasing horses on
his own account in 1988.
In late 1993, in connection with petitioner’s anticipated
retirement from Wal-Mart, petitioners decided to relocate to
Texas. In 1996, petitioners purchased a 212-acre ranch, the
"Diamond Spur Ranch", in Anderson, Texas (the Texas ranch). On
May 1, 1996, petitioners formed two limited liability companies:
“Dean Sanders Cutting Horse Ranch, LLC”, which lists its
principal business activity as horse breeding and training and
“Dean and Cindy Sanders Ranch, LLC”, which lists its principal
business activity as real estate. At the time of trial
(February 23 and 24, 1998), the Arkansas ranch was listed for
sale for $1.5 million.
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