Elizabeth Giles - Page 27

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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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