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Petitioner points the Court to a one-page fill-in-the-blanks
form with seven headings (including one for the name of the
business and another one for the year) that she alleges is a
legitimate and sufficient business plan for the horse activity.
We disagree with this assertion. This form on its face refers
specifically to 1991, and we are unable to find that petitioner
ever used this form to guide her in the horse activity as to any
year, not even as to 1991. The claim of usefulness of the form
as a business plan also suffers from the fact that (1) neither it
nor petitioner’s testimony specifies when it was prepared, (2)
petitioner never filled in a line on the form that references the
manner in which revenue in the activity may increase, although
the activity in its 3 years of existence from 1988 through 1990
had generated minimal revenues and had experienced losses
totaling almost $100,000, and (3) petitioner failed to conduct
the horse activity consistently with lines on the form that were
filled in. As to the latter, the form states that petitioner
will (1) sell the Falling Water Way property, (2) start showing
Silent Reign, (3) build on the Gavilan Hills property, and
(4) “breed, show, sell”. Petitioner has never done any of the
first three enumerated items. Nor as to the fourth enumerated
item has she consistently bred, shown, and/or sold her horses
from 1991 to date. While petitioner did show two of her horses
occasionally from 1992 to 2000, she did not show any of her
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