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In starting up her horse activity, petitioner spoke with
several individuals about training and breeding and about
veterinary issues relating to horses. In particular, petitioner
spoke with an award-winning breeder of Arabian horses, two horse
trainers, and a veterinarian. Petitioner consulted these
individuals regarding breeding horses, selecting stallions and
mares, feed, training methods, artificial insemination of mares,
and factors that could result in early termination of pregnancy.
Petitioner also spoke with individuals affiliated with horse
breeding and training who had been audited by respondent, who
recommended to petitioner that she keep good expense records and
that she keep track of receipts.
Aware that, as a physician, her horse activity would be
“under the microscope”, petitioner consulted a C.P.A. to learn
how to keep track of receipts and to maintain records.
Petitioner did not discuss with anyone the economic or
business aspects of breeding, training, and showing horses.
The following schedule indicates when petitioner acquired
each of her horses, the purchase price, the type of horse, if in
the record the purpose for purchasing the horse, and the horse’s
physical condition.
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Last modified: November 10, 2007