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We do not find Mr. Stewart’s conclusory report to be of any
assistance to the Court and accordingly disregard it.
On the whole, we conclude that this factor weighs against
petitioners.
B. Expertise of Petitioners and Their Advisers
Dr. Prieto had no significant experience with horses prior
to starting the horse activity. Mrs. Prieto’s only experience
with horses was riding them as a child and a teenager.
Petitioners claimed to have talked with many professionals before
entering the horse activity. These conversations, however,
mainly focused on the fact that a person could make a lot of
money or lose a lot of money buying and selling horses.
Petitioners did not discuss how to conduct the horse activity to
make it profitable, how to train the horses, or how to manage the
horse activity. Other than being advised to “get a trainer”,
petitioners received no useful advice before beginning the horse
activity. This factor also weighs against petitioners.
C. Time and Effort Expended by Petitioners
Mrs. Prieto claimed to work 40 hours a week, and Dr. Prieto
claimed to work 20 to 30 hours a week, in the horse activity.
Other than petitioners’ self-serving, conclusory statements,
there is no evidence to support this assertion. Dr. Prieto is an
orthopedic surgeon. Mrs. Prieto works in his office and spends a
considerable amount of time doing so. According to Nicole,
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