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horses in the possession of the Shortinos. Christopher testified
that petitioner was not involved in the horse activity and that
she did not make any decisions relating to the activity.
Mr. Rowe testified that he made the original decision to
start the horse activity and that he did not discuss it with
petitioner. Mr. Rowe considered the activity principally his,
and he included his children in the activity. Mr. Rowe testified
that he made all decisions regarding the horse activity and told
petitioner nothing about the horse activity. Additionally, Mr.
Rowe testified that he did not consult petitioner before starting
the fish activity, and he did not believe she wrote any checks in
connection with the fish farm. With respect to the fact that
petitioner’s name was listed as a proprietor on the 1987, 1988,
and 1989 tax returns, Mr. Rowe testified that the 1987 and 1988
returns were filled out by another individual and he simply
signed them without reviewing their contents. As we have
mentioned previously, the record indicates that petitioner was
given the first two pages only of the tax returns when signing
the returns, and she was not afforded the opportunity to see or
review any attachments, schedules, or other documents pertaining
to the returns.
The Shortinos testified that the checks they received for
their services as horse trainers while employed by Mr. Rowe
always came from him and never from petitioner. Our review of
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