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of Feyras Raehele, a $21,300 portable shelter, $1,975 of
improvements, and a $1,700 saddle and tack).
In 1989 through 2002, petitioner acquired seven more horses,
two by purchasing them and five through breeding as discussed
infra. She reported on her Schedules C for those years that the
name of her horse business was “Falling Water Arabians”, and she
reported on her 1989 through 1992 Schedules C that the address of
this business was that of the Falling Water Way property.4 On
her 1989 through 1991 Schedules C, she reported that the
“principal business” of Falling Water Arabians was “Horses”. On
her 1992 through 2002 Schedules C, she reported that the
“principal business” of Falling Water Arabians was both
“Breeding” and “Competing Horses”.
During the subject years, petitioner did much of the
feeding, cleaning, grooming, and training of her horses, which in
those years numbered four and three, respectively, and she did
all of the horses’ worming and vaccinations.5 She spent 30 hours
per week with the horses, consisting primarily of time spent on
the 3 days of the week that she did not work for Giles Inc. but
also including time spent on each of the other 4 days of the
4 The 1993 through 2002 Schedules C left blank the lines for
the address of Falling Water Arabians.
5 The record does not reveal the frequency or number of
times that petitioner wormed or vaccinated any of her horses or
the amount of time that she devoted to those services.
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