Thomas B. Drummond - Page 9

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          of those risks until Moonshadow became lame sometime during 1990,           
          approximately 18 months after petitioner had acquired it.                   
               Petitioner had physical examinations, x-rays, and blood work           
          performed on Moonshadow.  However, the cause of Moonshadow's                
          lameness was not determined.  Although petitioner provided                  
          Moonshadow with bed rest and took certain measures to alleviate             
          the horse's pain, he was unable to rehabilitate it.  Around 1995,           
          petitioner donated Moonshadow to the Virginia Polytechnic Insti-            
          tute (VPI).                                                                 
               Although petitioner became aware of the risks associated               
          with owning a gelding after his experience with Moonshadow during           
          1990, he nonetheless decided to purchase another gelding because            
          geldings were considered to be the most valuable show horses.               
          Consequently, sometime during 1990, after Moonshadow became lame,           
          petitioner purchased for approximately $8,000 another gelding, a            
          five-year old named Gator (Gator) that already had had some                 
          minimal training.  Sometime during or after the spring of 1994,             
          petitioner retained the services of a horse trainer who worked              
          with Gator on suppling exercises on the flat, lead changes, and             
          consistency in the show ring.  At unspecified times after the               
          purchase of Gator, petitioner entered it in certain horse shows             
          not for the nominal prize money, but for the recognition that it            
          might gain that would make it attractive to potential buyers.               
          Gator, however, exhibited certain difficulties that will prevent            
          it from ever becoming a show horse of great value.                          

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