Richard J. and Melodie D. McKeever - Page 11




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                  Paso fino horses are shown in three categories:  Pleasure,                           
            performance, and classic fino.  The categories are based on the                            
            horses’ ability to perform the gaits required of each class.                               
            Classic fino is the quickest, most difficult gait to perform, and                          
            horses able to perform classic fino are the most sought after                              
            within the paso fino breed.  Classic fino horses that win at the                           
            national level are worth at least $50,000, and a champion mare is                          
            valued at $250,000 or more.  Petitioners hoped to acquire horses                           
            that could compete and be sold in the classic fino market.                                 
                  The market for paso finos, especially classic fino horses,                           
            is concentrated in Florida; some sales of high-priced horses,                              
            however, have occurred in California.  During the years in issue,                          
            petitioners marketed their horses by advertising in regional                               
            publications, such as the California Horsetrader, and by posting                           
            flyers at their local feed stores.                                                         
                  Petitioners claimed advertising expenses on their Federal                            
            income tax returns of $380 for 1992 and zero for 1991 and 1993.                            
            In contrast, petitioners’ expense journals show advertising                                
            expenses of $372 in 1991 and $486 in 1993.  The expense journals                           
            do not indicate petitioners’ total advertising expenditures for                            
            1992.                                                                                      
                  Petitioners have held open houses and fun shows at their                             
            ranch, where potential customers may test ride the horses.                                 
            Petitioners’ E-mail address is Pasolove@aol.com.  Petitioners did                          





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