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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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