Victor A. and Marion W. Prieto - Page 5




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          Claire and Jill had participated in since 1987.  Prior to 1987,             
          when Jill and Claire got involved with horses, Mrs. Prieto had no           
          experience with show jumpers or showing horses.  Petitioners told           
          Jill and Claire if they wanted to participate in horseback riding           
          and perhaps compete on a high level, then petitioners would start           
          the horse activity.                                                         
               B.   Startup                                                           
               Starting in May 1991, petitioners engaged in a horse                   
          activity under the name Fordham Farms that included purchasing,             
          training, showing, and selling “hunter”, “jumper”, and                      
          “equitation” horses.  None of the horses in the horse activity              
          were held for breeding or bred.                                             
               “Hunter” is a category of horse competition that grades each           
          horse on its form, style, and technique as the horse competes on            
          a course of multiple hurdles.  “Jumper” is a category of horse              
          competition that grades the horse and rider on their ability to             
          jump fences cleanly and quickly.  The courses have tight turns              
          and angled fences making the jumps more difficult than those in             
          the hunter category.  “Grand Prix Jumper” is a category of horse            
          competition that also grades each horse on its ability to jump              
          fences cleanly and quickly; however, the courses are of a higher            
          difficulty than in the jumper category (higher fences, multiple             
          hurdles, etc.).  “Equitation” is a category of horse competition            








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