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The evidence does not establish and respondent has not
argued convincingly that any particular expense was unnecessary
or excessive. Obviously, keeping and maintaining horses is
expensive. Petitioner demonstrated that she has done what she
can to keep costs down, from choosing less expensive travel to
sharing the cost of a table at the club. Respondent offers
numerous ratios of the expenses associated with the equestrian
activities to the profit from Topping White. Petitioner does
what is necessary to maintain her reputation in the equestrian
world, and we find that she does not do so in an extravagant
manner. The fact remains that petitioner’s design business
depends heavily on her equestrian-related activities for its
success. We therefore find and hold that not only are
petitioner’s equestrian expenses ordinary and necessary, but that
they are reasonable in amount.
Conclusion
Petitioner’s equestrian and design activities constitute a
single undertaking. In addition, the expenses associated with
the equestrian-related activities are ordinary, necessary, and
reasonable in amount.
To reflect the foregoing and concessions by petitioner,
Decision will be entered
under Rule 155.
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Last modified: November 10, 2007