Roderick P. Strickland and Linda G. Strickland - Page 6




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          support the activity.                                                       
               Petitioners enlarged their old barn, built a new barn, and             
          added stalls, wash racks, an indoor arena, and an office.  Mr.              
          Strickland did much of the work.  Petitioners asked their                   
          certified public accountant how to set up their records.  They              
          asked successful breeders about the type of horses to acquire for           
          their horse activity.  They considered acquiring a stallion, but            
          owning a stallion would require them to modify their facilities             
          to do so.  Petitioner ran the daily operations of their horse               
          activity.  They intended to promote their activity by being                 
          successful at horse shows.  Petitioners did not have a written              
          business plan.                                                              
               2.   Horses That Petitioners Acquired, Bred, and Sold                  
               Petitioners owned 1 horse at the end of 1992, 4 at the end             
          of 1993, 5 at the end of 1994, 11 at the end of 1995, and 12 at             
          the end of 1996.  Petitioners bought, foaled, and sold horses as            
          follows:                                                                    


















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