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respondent ($8,080) from the total of petitioner’s deposits into
her general business account ($107,883.48).
III. Horse Activity
Petitioner has been involved with horses since she was 5
years old. She is familiar with training, breeding, and showing
horses.
In 1985, petitioner began to join saddlebred horse
associations and became more involved in horse-related activity.
From 1988 to 1996, petitioner belonged to 11 different
organizations related to her horse activity. Petitioner
maintained a library of books and video tapes concerning training
and breeding of horses and related subjects. From 1986 to 1989,
petitioner visited farriers and horse farms to determine ways to
generate income from horse activity. Based on advice she
received, petitioner decided to purchase and/or breed a stud
horse to generate revenue. Petitioner intended to show the
stallions, and any other horses of the same bloodline, as a means
of advertisement. Petitioner concluded that more income could be
generated from selling a stallion’s stud services than could be
generated from showing horses. Petitioner did not prepare any
profit projections prior to commencing her horse activity.
In 1989, petitioner began her horse activity by hiring a
well-qualified horse expert to acquire a horse on petitioner’s
behalf. The horse so acquired was Misty, a yearling saddlebred.
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