Michael T. Shane - Page 4

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          also spent a significant amount of time at racetracks observing             
          racehorses in action.                                                       
               This study period culminated in 1982 when petitioner                   
          acquired2 his first horse, Andiamo Bella, in a claiming race.3              
          Petitioner was of the opinion that Andiamo Bella had numerous               
          characteristics of a successful racehorse but that she had                  
          received poor training.  In acquiring Andiamo Bella, petitioner             
          felt that the negative effects of her prior training could be               
          overcome through the application of proper training.  After                 
          undergoing petitioner's personal training regimen, Andiamo Bella            
          proved profitable, winning approximately $65,000 during the 18-             
          month period ending with 1983.                                              
               Motivated by his success with Andiamo Bella, petitioner                
          began to expand his enterprise in 1984.  By 1987, petitioner                
          owned eight horses.  In response to having been unable to attain            
          results similar to those achieved with Andiamo Bella in 1983,               
          petitioner began enlarging the scope of his operation to include            
          horse breeding in 1986.  Consequently, petitioner has been a                
          member of the Maryland Horse Breeders Association since 1986.               


               2Petitioner actually acquired a 50-percent interest in his             
          first horse in 1982.  Eventually, however, petitioner acquired              
          the remaining interest in this horse.                                       
               3Generally speaking, a claiming race is a race specified by            
          race officials in which an interested party can "claim" or                  
          purchase the winning horse from its owner.  In order to claim a             
          horse, the interested party must tender a specified dollar amount           
          to the owner of the horse within a specified period of time.                




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