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At all relevant times, Richard J. McKeever was the sole
shareholder, chief executive officer, and general sales manager
of Aero Industrial Alloy, Inc., a metals distributing business.
Mr. McKeever does not hold a college degree.
Since at least 1986 and continuing through the date of
trial, Melodie D. McKeever has been employed full time as a
medical technologist by Kaiser Permanente. Mrs. McKeever
received a bachelor of science degree in microbiology, with an
emphasis in premed for veterinarians, from Long Beach State
University in 1972.
Mrs. McKeever has been involved with horses her entire life.
As a child, Mrs. McKeever spent time with horses on her
grandfather’s and uncle’s ranches. When her father was stationed
in Barstow, California, Mrs. McKeever cleaned stalls and did
other volunteer work at the U.S. Marine Corps stables in exchange
for lessons in riding and horsemanship. From 1975 until 1983,
Mrs. McKeever was a member of Equestrian Trails, Inc., an
organization devoted to maintaining trails throughout California.
Mrs. McKeever served as the secretary of her local chapter for 2
years. Prior to 1988, Mrs. McKeever owned two horses: A grade
gelding and a quarter horse mare.
Commencement of the Horse Activity
In 1987, petitioners began their horse activity.
Petitioners did not have any prior employment history or business
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