Sandra J. Brannon - Page 4




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          business nor petitioner's job related to horse breeding.                    
          Petitioner left that employment in October 1997 and did not                 
          thereafter accept any other employment.  She continued living               
          with her parents, devoting her entire time to the horse breeding            
          activity.  Petitioner has never paid rent or subsidized her                 
          parents for her living accommodations even during the period she            
          was gainfully employed.  In addition to providing petitioner with           
          her room and board, petitioner's father also provided her with              
          some financial assistance.                                                  
               Petitioner's horses have always been on a tract of land of             
          approximately 10 acres located about 25 miles from petitioner's             
          parents' residence.  The property consisted of a pasture with               
          some trees and a barn or shed.  Petitioner and her father leased            
          the property.  Another individual, Cecil Valdez, used the same              
          property for his horses.  Mr. Valdez did not pay any rent for his           
          use of the property.                                                        
               As noted earlier, petitioner commenced her activity with one           
          horse, then another, and owned six horses during 1993 and 1994.             
          Based on the testimony at trial, it appears that quarter horses             
          can be bred and trained in certain categories, which petitioner             
          and her father described generally as (1) western, (2) pleasure,            
          (3) halter and trail, and (4) cutting.  Petitioner directed her             
          activity toward the first three named specialties, although she             
          later realized that her chances for profit would be greater with            





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