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watered, administered necessary medications to, exercised, and
trained her horses. In addition, petitioner cleaned stalls.
During the years in issue, petitioner showed two of her
horses, Bogaz and Kart Blanche, five to six times per year. She
did not show her other horses during the years in issue. At the
shows, petitioner often rode the horses herself. Petitioner
received only a few hundred dollars for showing the horses from
1999 through 2001. In 2001, petitioner switched to the show
discipline of dressage.3
During the years in issue, petitioner did not ride her
horses in parades. Petitioner did not attend any social or
charity events relating to horses.
From 1988 to 2003, petitioner did not provide any services
to third parties, including training, coaching, or boarding.
From 1988 through 2000 and from 2002 through 2004, petitioner did
not sell any horses. In 2001, petitioner sold only one horse,
Bogaz.
2. Petitioner’s Horses
In 1999 and 2000, petitioner owned the following horses:
Feyras Raehele, Kart Blanche, Borissa, and Bogaz. Petitioner
3 “Dressage” is a disciplined practice in which the horse
is controlled in certain difficult steps and gaits by slight
movements of the rider. Dressage is a competitive event in the
Olympic Games, the Pan American Games, and other competitions.
There are two introductory levels of dressage, four separate
training levels, and four separate competitive levels.
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