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II. Petitioner’s Advisers
Petitioner consulted with various advisers in conducting her
thoroughbred horse breeding and racing activities. She employed
a professional breeding manager, professional trainers, and a
certified public accountant (CPA).
Petitioner employed Joseph McMahon (McMahon) as her breeding
manager from the time she began her breeding activities in 1982
through 1996, the year at issue. He is the operator of McMahon
Farm, located in Saratoga, New York, approximately 255 miles from
petitioner’s residence in New Jersey. McMahon Farm has
approximately 500 acres, boards between 150 and 300 horses, and
employs 14 full-time employees year round. It also occasionally
retains the services of varying numbers of seasonal employees.
McMahon cared for the day-to-day needs of petitioner’s breeding
horses and maintained breeding records for the breeding horses.
Petitioner frequently consulted with McMahon and relied upon
his advice regarding her thoroughbred horse breeding and racing
activities. He has approximately 90 thoroughbred horse breeding
clients. His farm produced Funny Cide, a gelding who won the
Kentucky Derby and the Preakness Stakes in 2003.
Petitioner employed different training managers during the
course of her thoroughbred horse breeding and racing activities.
These trainers were based in New York, Florida, and South
Carolina. Petitioner employed trainers in Southern States
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