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McKeever’s horse background, petitioners’ conversations with
trainers, or Mr. McKeever’s study of bloodlines, but the record
does not reflect that petitioners had any background in the
business or economic aspects of horse breeding, showing, and
selling, or that they sought advice prior to beginning the
activity from those who did.
Petitioners purchased their first paso finos in 1987.
There is no evidence that petitioners chose paso finos for their
horse activity after consultation with expert advisers.
Petitioners did not seek advice from Ms. Sarnecky or Mr. Minter
until the following year. Although petitioners referred to Mr.
Minter as a breeding and sales consultant, Mr. Minter was not
paid for his advice. Both Mr. Minter’s testimony and
petitioners’ testimony concerning the advice Mr. Minter gave to
petitioners were vague. At best, it appears that the advice was
general advice regarding showing and promoting horses, not
business advice. While Mr. Minter’s credentials are impressive,
petitioners presented very little evidence that they sought
advice from Mr. Minter on how to run a profitable horse business.
On the record before us, we conclude petitioners did not
investigate the economic viability of their proposed horse
activity prior to its inception in 1987, nor did they consult
with knowledgeable experts concerning the economic and business
aspects of their horse activity.
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