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In 1992, petitioner husband (Mr. Rozzano) was hired to be
the president of Armour Swift Eckridge, Inc., a publicly held
corporation. Mr. Rozzano’s new position required that he
relocate to Chicago, Illinois, which was approximately 5 hours
from their residence. At this time, petitioners decided that
instead of selling the property, which they had dubbed “Sugar
Tree Farm” (Sugar Tree), they would try to operate a horse-
boarding business.
Between 1992 and 2002, Mr. Rozzano changed jobs at least
twice, as he was hired in 1999 to be the executive vice president
and sales manager for Thorn Apple Valley, Inc., and in 2000, he
was hired to be the senior vice president and general manager of
Plumrose, U.S.A. During 1999, petitioners resided approximately
5 hours away from Sugar Tree in West Bloomfield, Michigan, while
Mr. Rozzano worked at Thorn Apple Valley, Inc.
After relocating to Chicago in 1992, petitioners began their
horse-boarding activity. This activity made use of the 27 stalls
housed in the barn at Sugar Tree, an indoor arena, and the
adjacent fields. Because petitioners resided more than 350 miles
from Sugar Tree, they employed at least one person to look after
the property and run the day-to-day operations taking place
there.
Between 1993 and 2003, when Sugar Tree was sold, petitioners
rented a great number of the 27 available stalls for horse-
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