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veterinary services, and 4) $2,135 and $2,450 for farrier
(blacksmith) services.
We also believe that it is evident that petitioner gains
personal pleasure from the horse activity. She testified that
she was compelled to buy her first horse because she had been
away from horses for awhile. She also admittedly rode her horses
during the relevant years in the wilds of the undeveloped (and
most likely scenic) 11.53 acres of the Gavilan Hills property.
To our minds, such riding on that property was more conducive to
pleasure than to pure training, the latter of which most likely
could have been done in the arena that petitioner had purchased
(or built) approximately 1 year before purchasing the Gavilan
Hills property. We also note that petitioner throughout her
testimony repeatedly referred to her horses as her “babies” and
opted not to dispose of her “babies” even when they were aged,
unable to breed, expensive to maintain, and/or unprofitable.28
This factor favors respondent.
10. Additional Factor
Petitioner did not on any of her 1988 through 2002 Schedules
C deduct interest or taxes paid as to the Falling Water Way
property and the Gavilan Hills property. We consider this fact
28 For example, she has kept Feyras Raehele at the Falling
Water Way property but has not bred it since 1988, and she has
kept Silent Reign at that property even though she sold it to her
daughter in 1997.
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