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continued through 1998.4 Our conclusion would be the same whether
or not we considered post-1995 events.
To reflect the foregoing,
Decision will be entered
under Rule 155.
4 Petitioners sold one horse for $24,000 in 1996. This
appears to be an anomaly because the sales prices of all of the
other horses that they sold after 1995 were similar to sales
prices before 1995. Petitioners received the notice of
deficiency in this case in 1997, and they expanded the number of
higher quality broodmares in 1998. Petitioners’ actions after
1997 may have been influenced by the pendency of this case and
show little or nothing about their intent in 1995. See Taube v.
Commissioner, 88 T.C. 464, 482 (1987); Lundquist v. Commissioner,
T.C. Memo. 1999-83; Brockenbrough v. Commissioner, T.C. Memo.
1998-454.
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