- 5 - cutting horses. She, therefore, changed her operation to that specialty. It is that change that petitioner claims resulted in her realization of a net profit for 1998. Petitioner regularly attended horse shows, was a member of various associations related thereto, had business cards, and advertised in trade journals or newspapers. Petitioner's sales of horses, however, were minimal. The purchaser of three horses was Cecil Valdez, who owned other horses at the same location with petitioner. Another purchaser was an unrelated party. Petitioner was of the belief that a market for her horses would be in Mexico; however, that did not materialize because of the decline in value of the Mexican peso. Petitioner also attributed her losses to the fact that she did not have a sufficient number of brood mares and that the bloodlines of her horses were not of the quality that would be in demand. She claimed that her chances of success would be enhanced by specializing with cutting horses rather than the other specialties stated above. She acknowledged her goal was to produce a $100,000 horse; however, to do that, she would be required to pay breeding or stud fees of at least $10,000, which she was not capable of doing. During the years at issue, petitioner paid $750 for stud fees. With respect to participation in horse shows, participants were either professionals or amateurs. Petitioner always participated as anPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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