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training process because she believed it was it was better than
other methods, and it was cheaper than using a horse trainer.
Petitioner also sent horses to trainers for additional training.
Petitioners advertised individual horses for sale in a local
newspaper. They did not insure horses they foaled or any horse
worth less than $20,000.
4. Petitioners’ Boarding and Leasing Activity
Petitioners decided to board horses beginning in December
1995 to help generate more income. Based on the cost of feed,
hay, sawdust, labor to clean stalls, electricity, and insurance,
they concluded that it would cost about $95 per month to board a
horse for a customer. They hired an attorney to write a form
contract and release of liability form to use for boarding
horses. They had the forms printed.
Petitioners boarded two horses in January and February 1996,
three in March, six in April, four in May, five from June to
August, six in September, five in October, seven in November, and
four in December. They obtained customers through referrals.
Petitioners retained an attorney to write a horse lease
agreement form which they had printed. Petitioners leased
Tequila Twist and Babes Little Luck to local 4-H Clubs for $175
per month each from December 1, 1995, to October 31, 1996. The
4-H Club members rode the leased horses on petitioners’ property.
As a favor to the lessees, petitioners sometimes hauled the
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