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organizational and economic relationship exists between the
equestrian and design undertakings. Petitioner’s success as an
equestrian competitor creates goodwill that benefits her design
business. See Keanini v. Commissioner, supra. Petitioner formed
the equestrian and design undertakings as a single integrated
business. Petitioner had been a competitor for most of her adult
life, and she transformed this sport experience into an avenue to
establish goodwill as an interior designer of horse barns and
second homes. She had a plan for an integrated equestrian-based
design business. Petitioner and her assistant manage and oversee
both undertakings and their assets and also use the same books
and records to track both undertakings.
Further, petitioner’s equestrian activities significantly
benefit her design business, and we find a significant business
purpose for the combination of these undertakings. Her
prominence as a competitor has gained respect among her peers and
causes them to seek her out when they are in need of a designer
for their horse barns and recreational homes.
Respondent faults petitioner for not advertising in a
conventional sense, such as putting up ads in equestrian
magazines or banners at horse shows. Respondent argues that
petitioner’s failure to specifically advertise the name of
Topping White through conventional media is indicative of the
lack of an economic relationship between the two undertakings.
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