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In the 1990 annual plan, petitioner listed her long-term
goals as “Breeding/Selling” and “Training horses for added
value.” Under “plans for next year,” petitioner listed “Seek
better trainer with better reputation.”
In the 1991 annual plan, petitioner listed her long-term
goals as “Sell * * * [Falling Water Way] to set up business in
* * * [Gavilan Hills] for expansion. Breed, Show, Sell.”
In the 1992 annual plan, petitioner listed her long-term
goals as “Move to Gavilan Hills for expansion.” Under short-term
goals, petitioner listed “TF Silent Reign to Nationals with David
Garrett.” David Garrett is a trainer with whom petitioner
consulted about breeding, training, and showing.
In the 1993 annual plan, petitioner listed her long-term
goals as “Move to Gavilan Hills . . . Breed & Sell.” Under
“Changes/Decisions to Decrease Chances of Failure and Increase
Revenues,” petitioner stated “self train and self vet.”
In the 1994 annual plan, petitioner listed her long-term
goals as “Same as ‘93 Goals.” Under “successes,” petitioner
stated “Found Lou Roper.” Petitioner consulted with Lou Roper, a
national champion in the discipline of trail and hunting
pleasure, on horse training.
b. General Business Plan
Petitioner and Ms. Pope also prepared a “general business
plan” concerning petitioner’s horse activity. Similar to the
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Last modified: May 25, 2011