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those cases have the same level of integration and
interdependence that petitioner’s equestrian and design
activities did. We are persuaded that petitioner’s equestrian
activities are necessary to the success of her design business.
In the equestrian-related cases that respondent cites, it is
apparent that the recreational activities were an afterthought to
the taxpayer’s primary business, and were more of a social
opportunity than an integrated part of a symbiotic business plan.
In both De Mendoza and Wilkinson, the Court found that the
benefit of the ranching activities was “incidental” to the
taxpayers’ law and medical practices, respectively. Similarly,
in De Mendoza, we were not convinced that the taxpayer’s polo
activity materially benefited his business. In Zdun v.
Commissioner, only 10 to 15 percent of the taxpayer dentist’s
patients actually took the apples he offered, even when he
provided the apples to them for no cost.
Here, virtually all of petitioner’s clients are equestrian-
related contacts who depend on her knowledge and expertise of
horses in designing their barns and homes. In addition, the
success of petitioner’s interior design business is far from
incidental to her equestrian contacts. The evidence shows,
rather, that petitioner’s interior design business materially
benefits from her equestrian-related activities, which is
consistent with the distinctions made between incidental and
material benefit in De Mendoza and Wilkinson. The evidence
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