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hour shifts and one 12-hour shift. Petitioner preferred this
work schedule because she felt “burned out” from medical school
and because it gave her more full days to spend with her six
children.
For the years in issue, petitioner’s average annual income
from her medical practice was $238,134.
Petitioner’s husband Richard Shearer was employed as a
firefighter-medic in North Dakota and did not participate in any
meaningful way in petitioner’s horse activity.
Throughout her life, petitioner admired horses. While in
high school, petitioner worked part time in a veterinary clinic
and was a member of several riding clubs. Petitioner purchased
and boarded her first horse when she was 15 years old.
In 1996, when petitioner began her horse activity,
petitioner realized a lifelong dream of working with horses.
Petitioner was particularly interested in raising Arabian
horses. Petitioner considers Arabian horses the “ballerinas of
the horse world”.
Prior to 1996, petitioner had no experience in the business
of buying, selling, or showing horses. Petitioner did have
experience in owning, caring for, and riding horses, and
petitioner possessed the knowledge and skill to perform basic
veterinary tasks.
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