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etorship continued using the remaining 10 such horses in its
business. As discussed below, petitioners reported in their 1998
tax return the following gain or loss on the sale of those nine
horses:
Horses Gain or (Loss)
Idealists Hanover ($1,839)
Brief Wars 2,129
Western Skylark 129
Rare Guy (3,779)
Overture Siera (3,319)
Happening Hanover (2,883)
Yankee Skylark 1,199
Overture Hanover (911)
Vidalita Hanover (2,267)
In 1999, Mr. Ramsburg sold three additional racing and
breeding horses that Kildare Timmy had distributed to him, and
Mr. Ramsburg’s sole proprietorship continued using the remaining
seven such horses in its business. As discussed below, petition-
ers reported in their 1999 tax return the following gain or loss
on the sale of those three horses:9
Horses Gain or (Loss)
Bar B Wars ($2,067)
Justen’s Western 58,933
Western Shuffle 30,301
In 2002, Mr. Ramsburg sold three additional racing and
breeding horses that Kildare Timmy had distributed to him. As
discussed below, petitioners reported in their 2002 tax return
9See infra note 16.
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