Sandra J. Brannon - Page 5




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          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 an            





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