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After his experience with Moonshadow during 1990, petitioner
concluded that if he were to purchase either a mare or a stallion
and that horse were to become lame or otherwise to lack athletic
ability, it could still be used for breeding purposes. Sometime
during 1990, after Moonshadow became lame, petitioner purchased
for approximately $3,500 to $4,000 a proven broodmare, a four-
year old thoroughbred named Jill (Jill) that had had no training
except for training in accepting a rider. Thereafter, around
1990, petitioner rode Jill, concluded that it did not possess the
characteristics necessary for a show horse or a competitive
horse, which he did not realize when he purchased Jill, and
decided to use it only for breeding purposes.6
Around 1990, petitioner bred Jill to an internationally
acclaimed dressage Trakehner stallion, even though he knew that a
crossbreeding of a thoroughbred and a Trakehner would probably
require that any male offspring be gelded. During 1991, the
crossbreeding of Jill produced a colt named Zack (Zack) that was
gelded within nine months thereafter.
Around 1992, when Zack was a year old, it was trained to
accept a lightweight rider. Around 1995, when Zack was a three-
year old, it was trained to accept a rider of normal weight and
6 Any horse that petitioner acquired through the breeding of a
mare such as Jill (1) would not be ready for serious training
until the age of two at which time it could support a rider;
(2) could not perform and compete as a show horse until the age
of three; and (3) could not become a show horse of great value
until at least the age of six.
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