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Mr. Stottlemeyer’s note did not specify any date(s) on which Mr.
Stottlemeyer was to make any payment(s) thereunder.
At a time not disclosed by the record before petitioners’
taxable year 1996, Mr. Ramsburg began operating as a sole propri-
etorship a horse-racing business under the name Troy McDougal
(Mr. Ramsburg’s sole proprietorship).7 Mr. Ramsburg’s sole
proprietorship raced two- and three-year old horses. Mr.
Ramsburg’s sole proprietorship sold the three-year old horses
that he raced after the racing season ended. At all relevant
times, Mr. Ramsburg’s sole proprietorship retained Dan Altmeyer
(Mr. Altmeyer) to serve as the trainer for its horses. In return
for his services, Mr. Ramsburg’s sole proprietorship gave Mr.
Altmeyer a one-third interest in any horses that it purchased
(Mr. Ramsburg’s sole proprietorship’s horses). At all relevant
times, Mr. Altmeyer trained Mr. Ramsburg’s sole proprietorship’s
horses for half a year in Florida and for half a year in Pennsyl-
vania.
Beginning in 1995, Mr. Stottlemeyer became ill and was
diagnosed with a brain tumor. In the spring of 1995, Mr.
Stottlemeyer underwent surgery, which was followed by a long
recovery period. During the period Mr. Stottlemeyer was recover-
ing, Mr. Ramsburg assumed Mr. Stottlemeyer’s day-to-day manage-
7At a time not disclosed by the record during petitioners’
taxable year 1998, the name of Mr. Ramsburg’s sole proprietorship
was changed from Troy McDougal to J R Ramsburg Stables.
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