Elizabeth Giles - Page 35

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          horses, did it include specific business advice on how to start             
          and operate a horse breeding business profitably, did she follow            
          the advice?  Nor is there credible evidence in the record that              
          any of these purported experts were actually experts on anything            
          related to the conduct of the business of breeding and showing              
          horses (or even on the conduct of a business in general).  While            
          petitioner did testify generally that her daughter is a certified           
          public accountant, we know nothing else about her daughter’s                
          practice of public accounting (e.g., what is her specialty) or,             
          more specifically, whether she is an expert on the subject of               
          horse breeding and showing.  We also note as to this daughter               
          that each of petitioner’s 1988 through 2002 tax returns appears             
          to have been prepared by someone else.                                      
               Of course, petitioner has over the years acquired some sort            
          of hands-on experience on the subject of horse breeding from the            
          point of view of a horse breeder.  The record, however, does not            
          reflect that she has ever acquired any knowledge of the business            
          or economic aspects of horse breeding so as to be prepared for              
          the economic realities of a horse breeding and showing business.            
          We find nothing credible to suggest that she prepared for the               
          economic aspects of the activity by study or consultation with              
          experts, nor has she shown that, before starting the activity,              
          she had any idea of what her ultimate costs might be, how she               
          might achieve any degree of cost efficiency, the amount of                  






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