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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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