Tracey L. Topping - Page 25




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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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