Dennis L. and Margaret J. Knudsen - Page 16




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         present evidence that membership in these organizations increased            
         the marketability of their animals.                                          
              In addition, Mrs. Knudsen ordered business cards for ERE and            
         distributed them to potential business contacts.  ERE’s business             
         card featured a description of its business as “conservation,                
         preservation, rare and endangered species”, a small picture of               
         exotic animals, and Mrs. Knudsen’s name and contact information.             
         The business card did not indicate that ERE sold exotic animals.             
         Petitioners’ Sales Activities                                                
              Petitioners sold animals to individuals, brokers, and zoos              
         and through auctions.  Petitioners initially sold birds locally              
         but then decided to use a broker to send most of their birds to a            
         pet shop in Denver.  Petitioners determined the market prices for            
         their animals from various journals, including Animal Finders’               
         Guide and Rare Breeds Journal.                                               
              From 1995 through 2002, petitioners received $416,080 from              
         animal sales.  As stated above, the record provides little                   
         evidence regarding the details of petitioners’ sales activities.             
         Petitioners’ Time and Effort                                                 
              Petitioners devoted substantial time and effort to ERE.                 
         Although Dr. Knudsen devoted most of his time to his medical                 
         practice, he spent around 15 or 20 hours per week working at ERE             
         during the spring and summer months.  Dr. Knudsen attended to the            
         animals’ health needs and was the primary caretaker of the                   







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