- 13 - 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).Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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