Elizabeth Giles - Page 28

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                              Year      Veterinary Expenses                           
                              1988           $222                                     
                              1989           1,304                                    
                              1990           3,410                                    
                              1991           1,803                                    
                              1992           2,434                                    
                              1993           899                                      
                              1994           5,322                                    
                              1995           2,377                                    
                              1996           1,272                                    
                              1997           1,382                                    
                              1998           1,453                                    
                              1999           2,614                                    
                              2000           1,731                                    
                              2001           947                                      
                              2002           3,101                                    
                              2003           1,398                                    
          There is no discernable pattern to the reported veterinary                  
          expenses that would indicate veterinary costs decreased as a                
          result of petitioner’s performing some veterinary services on her           
          own.                                                                        
               Petitioner testified that, in 2001, she switched show                  
          disciplines from western pleasure and trail to dressage because             
          she perceived a greater demand for dressage horses.  Petitioner             
          presented no evidence that corroborates her perception.                     
          Petitioner did not indicate that her horses were marketed                   
          differently or how the switch in show disciplines would otherwise           
          affect the profitability of petitioner’s horse activity.                    
               On the basis of the above, we cannot infer that petitioner’s           
          decisions to halt breeding, perform veterinary services, or                 
          switch show disciplines were made in a manner consistent with an            
          intent to improve profitability.  Petitioner has not shown that             





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