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In 1991, petitioner purchased Rey, a registered palomino. In
1993, petitioner purchased a broodmare, Jolly Berry, for $8,000;
another broodmare, Fairy Dust, for $3,800; a third broodmare,
Trigger Happy, for $2,200; and a yearling gelding, Defy, for
$1,100. Petitioner made efforts to advertise her horses at
shows, in magazines, and within various associations.
Petitioner maintained separate records for each horse. The
records for each horse contained information regarding pedigree,
pictures and information about the sire and dam, medical history,
pictures of the horse, breeding information, medical information,
insurance information, and training records. Petitioner also
maintained numerous horse activity files. These files contained
information and documents, including: Forms, horses for sale,
health tips, boarding and training information, equipment
information, horse-related articles, and association membership.
For the years 1989 through 1995, petitioner reported income
and expenses and claimed losses from her horse activity as
follows:
Year Income Expenses Losses
1989 -0- $7,025 $7,025
1990 $305 12,838 12,533
1991 -0- 12,994 12,994
1992 447 19,667 19,220
1993 10,402 21,531 11,129
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