Victor A. and Marion W. Prieto - Page 9




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          selling it for either $75,000 as a “pre-green” or $125,000 to               
          $150,000 as a “first year green hunter”, and (4) selling “Rising            
          Sun” for $35,000 to $40,000.  Other goals were more general such            
          as purchasing and developing a grand prix horse and a junior                
          jumper, increasing the number of horses shown, and increasing the           
          use of trucks to transport horses.                                          
               Petitioners did not sell Fashion Page in 1994.  Petitioners            
          did sell Make Believe, Desire Me, and Rising Sun in 1994.  The              
          sale price and petitioners’ original purchase price of each of              
          these horses was as follows:                                                
               Horse               Purchase Price      Sale Price                     
               Make Believe        $22,500             $20,000                        
               Desire Me           22,500              16,000                         
               Rising Sun          1,000               1                              
               Petitioners' goals for 1995 were more general than those for           
          1994.  They included increasing hauling income, increasing their            
          client base, developing their horses, purchasing junior jumper              
          and equitation horses, getting their horses to the shows, and               
          having Nicole stay on as their trainer.                                     
               E.   Boarding the Horses                                               
               The horses and all other items necessary for the horse                 
          activity were maintained at the following locations (all located            
          in California):                                                             










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