Otis W. Jordan and Alma F. Jordan - Page 2

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               Some of the facts have been stipulated and are so found.               
          Petitioners are husband and wife.  They filed a timely 1994 joint           
          Federal income tax return.  At the time the petition was filed,             
          petitioners resided in Amissville, Virginia.  References to                 
          petitioner are to Alma F. Jordan.                                           
               During all relevant times, petitioners lived on a                      
          20-acre farm.  They constructed a new barn on their farm, or                
          substantially improved an existing one, during 1994.  Petitioners           
          own several thoroughbred race horses.  They acquired their first            
          race horse in 1986.  By 1994 they owned six broodmares that,                
          except when boarded at a race track during a racing season or               
          elsewhere for breeding purposes, were kept at their farm.  The              
          horses are not used for recreational riding purposes.  At least             
          two of the horses, Jordan’s Tan and Hilarious Astro, were entered           
          in various thoroughbred racing events prior to the year in issue.           
          During 1993 Jordan’s Tan earned purses totaling $6,208 from at              
          least 12 races at Charles Town Races, in Charles Town, West                 
               Petitioners intend to acquire a stable of race horses by               
          mating their broodmares with stallions owned by others.  Their              
          plan is to produce foals that, after appropriate training, will             
          develop into successful thoroughbred race horses.  Consequently             
          and typically, the primary source of income that petitioners                

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