Michael G. Bunney - Page 5

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          (Campos Horses), had about 15 to 20 full-time clients, with 3 of            
          them engaging in breeding or training as a business.  When                  
          petitioner first became a client of Campos Horses, he owned a               
          breeding stallion and was breeding paint horses.  Petitioner also           
          took riding lessons from Campos.                                            
               From January 1, 1995, through December 31, 1996, petitioner            
          was a member of the National Reining Horse Association (Reining             
          Association).  Petitioner let his membership expire at the end of           
          1996.  Petitioner was not listed with the Reining Association as            
          a trainer or breeder during the years in issue.  In March 2001,             
          petitioner signed a declaration with the Reining Association                
          stating that he had not trained or assisted in training for                 
          remuneration for the prior 5 years.  Neither petitioner nor M&S             
          was listed with the Reining Association as having collected any             
          lifetime earnings or points from Reining Association approved               
          shows.  Petitioner’s daughter, however, has ridden horses in                
          reining competitions in the youth categories.  Petitioner’s                 
          daughter earned $4.81 in lifetime earnings and 18.50 points in              
          Reining Association approved shows as of December 31, 2002.                 
          Petitioner’s Business Records                                               
               Petitioner maintained his business records using the                   
          computer software program known as Quicken.  Petitioner created             
          with the Quicken program a list of expenses for the years in                
          issue.  Petitioner did not maintain records of any bills from               

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Last modified: May 25, 2011