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H. Personal Nature of Activity/Elements of Pleasure
During the years in issue, petitioners and their children
spent almost every weekend with the horses. Dr. Prieto, Mrs.
Prieto, Jill, and Claire used the weekends spent with the horses
as their time to unwind. Jill and Claire would ride and take
lessons on the horses. Jill and Claire enjoyed riding horses.
Mrs. Prieto also rode the horses. In addition to watching their
daughters compete at the horse shows, petitioners attended
hospitality tents located at the horse shows.
In January 1994, petitioners sold a horse named “Browning”.
In a letter thanking the purchaser of Browning for buying the
horse, petitioners wrote that they would be using the money from
this transaction to purchase a quality junior jumper for their
daughter Jill.
Dr. Prieto only did “simple” tasks for the horse activity.
He felt that his college and medical education entitled him not
to muck4 the stalls.
During the years in issue, Mrs. Prieto, Claire, and Jill
were members of the following horse organizations: The American
Horse Shows Association, the Pacific Horse Show Association, the
California Professional Horsemen’s Association, the United States
Equestrian Team, and the NorCal Hunter Jumper Association. In
4 To “muck” means “to clear of manure or filth”. Merriam
Webster’s Collegiate Dictionary 762 (10th ed. 1996).
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