Michael T. Shane - Page 5

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          In 1988, following several years of poor results with regard to             
          the racing component of his enterprise, petitioner began                    
          concentrating his attention on horse breeding, though horseracing           
          remained a peripheral part of his activity.   This emphasis on              
          horse breeding remained petitioner's practice throughout the                
          years at issue.                                                             
               A principal factor underlying petitioner's decision to focus           
          on breeding was his belief that through a combination of                    
          successful breeding and proper training he could produce foals              
          that would appreciate substantially in value.  In accordance with           
          his desire to produce quality horses with established pedigrees,            
          petitioner bred his horses with two of the top-rated stallions in           
          Maryland.  Despite petitioner's efforts, however, prior to the              
          time of trial he had not attained significant acclaim as a                  
          successful breeder and had not sold any foals.                              
               Petitioner boarded his horses at a boarding facility located           
          approximately 20 miles from his residence.  According to                    
          petitioner, he spent several hours each morning and several hours           
          each night tending to his horses.  In tending to his horses,                
          petitioner performed a variety of activities.  The horses were              
          exercised, fed, and groomed.  Medications were administered, and            
          stalls were cleaned.  Not infrequently, petitioner's night-time             
          horse activity kept him at the boarding facility until midnight.            
          Often times, under those circumstances, petitioner slept in his             
          automobile at the boarding facility rather than travel the 20               




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