Michael J. Rozzano, Jr., and Rose Marie Rozzano - Page 4




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          boarding.  Typically, between 40 percent and 65 percent of the              
          stalls were rented at any given time.  During the taxable years             
          in issue, petitioners charged in the range of $375 per month for            
          each horse boarded at Sugar Tree.  In addition to the boarded               
          horses, petitioners kept their own horse and pony in the stables.           
          However, the last time that petitioners rode either horse was in            
          1990.                                                                       
               Mr. Rozzano applied his extensive business knowledge and               
          experience to the activity at Sugar Tree.  Using various computer           
          software programs, he compiled spreadsheets and projected budgets           
          for the activity.  He also performed most of the major upkeep on            
          Sugar Tree, including mowing the fields, mending horse fences,              
          mucking stalls, and also feeding horses on those days that he was           
          present at Sugar Tree.  According to Mr. Rozzano, during the time           
          that petitioners lived away from Sugar Tree (which was                      
          approximately 80 percent of the time of 1999 and some small part            
          of 2000), he would wake up each Saturday morning, drive                     
          approximately 5-plus hours from West Bloomfield, Michigan, to               
          Sugar Tree (Loveland, Ohio), spend 6 to 8 hours each day of the             
          weekend mowing, mucking, and mending, and then get back in his              
          car late Sunday afternoon and drive 5 hours back to West                    
          Bloomfield.  Mr. Rozzano testified that he made this trip every             
          weekend and holiday until they temporarily moved back to reside             
          full time at Sugar Tree sometime in 2000.                                   







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