Thomas B. Drummond - Page 10

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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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