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Throughout the years in issue, petitioner received and read
publications and materials regarding horse breeding and horse
training. Several of the publications discussed tax issues
relating to horse breeding.
Once petitioner began her horse activity, petitioner
retained her emergency room work schedule to allow more time in
her horse activity. On days not scheduled to work at the
hospital, petitioner spent approximately 7 to 10 hours working in
her horse activity.
Petitioner’s horse activity involved training and feeding
the horses, cleaning horse stalls, riding recreationally,
competing in shows, performing basic veterinary work, and a host
of other activities. Petitioner received much enjoyment and
satisfaction from her horse activity. Petitioner’s favorite time
of day was working with the horses, and petitioner even found
cleaning the stalls to be a “stress reliever”.
Ongoing care and training of the horses were performed by
petitioner and her family. Before showing, petitioner hired a
professional trainer to “finish” training the horses.
Petitioner’s daughter often rode in horse shows, and
petitioner was extremely proud of her daughter’s and her horses’
successes in the shows. On four occasions, petitioner’s horses
participated in national competitive horse shows.
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Last modified: November 10, 2007