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filed. Pursuant to section 7463(b), the decisions to be entered
are not reviewable by any other court, and this opinion shall not
be treated as precedent for any other case. The issue for
decision is whether petitioners are entitled to certain
deductions relating to their horse-breeding activity for 2002.
Background
At all relevant times, Paula Wilson and Michael Ryan
(collectively, petitioners) have been law enforcement officers.
In 1995, petitioners established Wilson Ryan Quarter Horses, a
horse training and breeding operation (the activity). Ms. Wilson
had significant experience in training horses (i.e., she began
training horses at age 9) and was responsible for the training of
petitioners’ horses.
Petitioners routinely woke up before 5:00 a.m. each day to
clean the horse stalls and feed the horses; returned from their
respective law enforcement duties at 5:00 p.m.; and fed, trained,
and cared for the horses late into the night. In addition,
petitioners kept continuous watch over the horses during breeding
and foaling seasons.
From 1995 through 2002, Ms. Wilson attended exhibitions and
advertised in trade magazines to promote Wilson Ryan Quarter
Horses. In addition, she consulted with trainers, doctors, and
nutritionists to care for the horses properly. Mr. Ryan
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