J. Michael and Susan Reimer - Page 10




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               Petitioners’ second plan, entitled “J-Mar Arabians 5 Year              
          Plan - Revised: 1975-1980" (revised 5-year plan), carried forward           
          the overall net loss of $8,500 from the 1971 business plan, and             
          continued to make projections through 1980.  At the end of 1980,            
          petitioners projected assets worth $19,450 and an overall net               
          loss of $18,650.                                                            
               Petitioners’ third business plan, entitled “J-Mar Arabians 5           
          Year Plan - Revision II: 1980-1985" (second revised 5-year plan),           
          also carried forward the projected net loss of $18,650 in 1980              
          (from the revised 5-year plan) as the starting point for the 1980           
          to 19892 projections.  According to the second revised 5-year               
          plan, petitioners would yield an overall net profit of $23,850 in           
          1988, or year 18.                                                           
               In 1985, petitioners drafted a proposed limited partnership            
          agreement for the purchase of a one-third interest in Sassafras             
          and Tender Moment by a third party.  Included in the proposal are           
          the following documents:  An estimated 5-year cashflow, estimated           
          fair market value of the horses (Sassafras valued at $200,000 and           
          Tender Moment valued at $300,000), payment terms, and cash                  
          reconciliation with depreciation.  This partnership was never               
          formed.                                                                     


               2    Petitioners’ financial projections were for the time              
          period 1980 through 1989, even though their business plan was for           
          the period 1980 through 1985.                                               






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