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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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