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petitioners hired to clean the stalls and groom, braid, and feed
the horses). Nicole’s background was as a “junior” rider;2 she
had no experience as a trainer or running a business. At this
time, Nicole had just turned 18 years old.
Petitioners hired other people besides Mr. Norick and Nicole
to work in the horse activity. Petitioners hired Scott Wilson as
an assistant trainer, Bill Nissen as veterinarian, Ms. Sasaki as
bookkeeper, Patrick Hurley as accountant for the horse activity,3
and Carlos Soriano as a groom. At horse shows, when the horse
activity needed extra help, petitioners hired people to braid the
horses, horseshoers, and a night watchman.
Petitioners sent the horse activity’s records to Ms. Sasaki
to sort the records into separate file folders, and each year
petitioners received a box from Ms. Sasaki with the records
sorted. Ms. Sasaki also inputted the financial records of the
horse activity onto a computer. Petitioners reviewed the books
and records of the horse activity and their tax returns.
D. How Petitioners Conducted the Activity
Petitioners created a logo for the horse activity and had
“business cards” and stationery that bore this logo. Petitioners
also used envelopes bearing the name Fordham Farms.
2 “Junior” refers to riders under 18 years old.
3 Petitioners had a separate accountant, Jay Witt, who
prepared their individual income tax returns.
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Last modified: May 25, 2011