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Petitioner called Dixon a couple of times from Virginia to
discuss the farm. Petitioner called the people responsible for
her farm at least twice a week while she was in Virginia.
Petitioner sold a horse named Fraulein Oneonta for $1,200
to an Oregon buyer in June 1988. Petitioner began working at
Foxcroft on July 1, 1988. Petitioner left some unmarketable
horses in Oregon and took four horses to Virginia. Petitioner
intended to have the horses she left behind shipped to her to
sell after they attained marketable age.
Petitioner was injured in September 1988. She suffered from
reflex sympathetic dystrophy and could not complete her duties
as headmistress of Foxcroft. In January 1989, the Foxcroft board
of directors relieved petitioner of her position. Petitioner
entered into a termination agreement with Foxcroft on
February 12, 1989.
C. Petitioner's Post-Foxcroft Activities
Petitioner lived at Salem Farm in Upperville, Virginia, from
March to May 1989. Petitioner went to her farm in Oregon twice
between January and May 1989.
In May 1989, petitioner permanently returned to her farm.
Petitioner gave two horses to Gerth Christensen (Christensen) in
August 1989. The record does not indicate why petitioner gave
the horses to Christensen.
From 1990 until the time of trial petitioner received
pension payments, completed some consulting contracts, and taught
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