Paula L. Wilson - Page 4

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          maintained the books and records and tended to the horses when              
          Ms. Wilson was unavailable.  Neither petitioner rode the horses             
          for pleasure.                                                               
               In 1997, petitioners sold five horses for a profit.                    
          Petitioners, however, believed that they needed to find a unique            
          type of horse to maximize their profit potential.  They                     
          researched several types of horses, concluded that Skipper W                
          horses were the best “all-around performance” horses, and in                
          October of 1996, bought Scotchcourt, a champion-bred Skipper W              
          mare.  In 1997, Scotchcourt produced a stallion, Buzz, that                 
          petitioners anticipated would become a profitable stud.  After              
          developing severe medical problems, however, he was not able to             
          do so.                                                                      
               In 2000, petitioners sold their 10-acre farm and purchased a           
          75-acre farm.  On the new farm, they maintained a hayfield to               
          feed the horses, three additional structures to house the horses,           
          and a barn with stalls and a riding area to facilitate the                  
          breeding and training of the horses.                                        
               In September 2001, Ms. Wilson was injured while on duty as a           
          law enforcement officer and, as a result, could not train horses            
          for approximately 1 year.  In the fall of 2002, Ms. Wilson                  
          suffered a broken collarbone and was unable to train horses for             
          another year.  In 2002, petitioners purchased a stallion, Scotch            

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