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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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