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In 2000, petitioner began building a barn to shelter the
horses during the breeding months and thereby to improve breeding.
In 2001, petitioner began boarding horses for, and leasing
horses to, other individuals and providing horse clinics.
During the years in issue, in an effort to reduce horse
activity expenses, petitioner changed types of feed and sought
out alternate sources of hay and specials on stud fees.
During 1996 through 2002, petitioner advertised that her
horses were for sale by word of mouth, by showing horses at horse
shows, by placing advertisements on three Internet Web sites, and
by posting notices at a saddle shop. Petitioner did not
advertise any of her horses for sale in any written publications.
In none of the years in issue did petitioner advertise the
boarding and leasing of horses.
During 1996 through 2000, from two checking accounts
petitioner paid both personal and horse activity expenses.
During 2001, from three different checking accounts
petitioner paid both personal and horse activity expenses.
In 2002, petitioner opened a checking account in the name of
Nora Ellen Keating Stony Creek Arabians and two new personal
checking accounts from all three of which petitioner paid both
personal and horse activity expenses.
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Last modified: November 10, 2007