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funds in 1994, but he kept as much as possible because they were
appreciating in value rapidly.
Mrs. Berry worked part time as the office manager for Dr.
Berry’s surgical clinic until he closed the clinic in 1995. Dr.
Berry has practiced medicine at the White River Rural Health
Service since then.
B. Petitioners' Farm
1. Starting the Horse-Breeding Activity
Dr. and Mrs. Berry bought a 127-acre farm in Roland,
Arkansas, in 1974 and moved to the farm in 1979. Petitioners
grew soybeans in 1979 and started a horse-breeding activity in
1980 which they called Berry Lane Farm.
2. Racking Horses
Petitioners decided to breed racking horses. Racking horses
and Tennessee walking horses have the same bloodlines. Tennessee
walking horses walk with at least three feet on the ground, over-
striding rear legs, a reaching motion in their front legs, and a
nodding head. Racking horses walk with at least one foot on the
ground, a folding motion in their front legs, and heads that are
steadier than those of Tennessee walking horses.
Petitioners decided to breed racking horses because they
thought racking horses were increasing in popularity faster than
any other kind of horse and were more affordable than Tennessee
walking horses. In addition, Mrs. Berry believed that the
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