J. Michael and Susan Reimer - Page 12




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          physical needs, e.g., taking the horses out to pasture, grooming,           
          feeding, and cleaning out stalls daily, while Mr. Reimer handled            
          all of the administrative duties, e.g., maintaining farm records,           
          paying bills, and preparing all tax returns.                                
               During the years in issue, both petitioners worked full-time           
          outside of their horse breeding activity.  Mrs. Reimer worked               
          with the horses before and after returning from teaching                    
          preschool on weekdays.  In a typical week, Mrs. Reimer spent 2 to           
          4 hours a day maintaining the horses, e.g., cleaning out the                
          stalls, feeding, grooming, and exercising the horses.  During               
          weekends, Mrs. Reimer would complete all of the barn chores,                
          spending from 3 to 6 hours on Saturday and Sunday.  Mrs. Reimer             
          testified that she tracked each horse’s “heat cycle” on a                   
          calendar for breeding purposes; however, the calendar was not               
          provided at trial.                                                          
               Mrs. Reimer is primarily responsible for training, grooming,           
          and preparing the horses for show.  She rode the horses every day           
          as part of their exercise and condition training for shows.  Mr.            
          Reimer assisted, on occasion, in preparing the horses for show,             
          which included warming up or riding the horses, although Mrs.               
          Reimer exclusively rode the horses during a show.  Mr. Reimer               
          typically assisted Mrs. Reimer about 1 hour per day in the more             
          labor intensive aspect of horse breeding in addition to the                 
          approximately 10 hours per week of administrative duties.                   







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