Tracey L. Topping - Page 16




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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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Last modified: November 10, 2007