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Company, Inc. (Pride Solvents).1 Mrs. Abbene was employed as a
registered nurse.
Mr. Abbene's Horse-Related Activities Before the Incorporation of
Blue Ribbon
Mr. Abbene's involvement with horses began when, at the age
of 17,2 he first owned and rode horses for pleasure. Mr. Abbene
has maintained horses for showing, riding, and breeding since
1971. Although Mr. Abbene was never formally trained to show or
breed horses, he was active in several horseman's associations
both before and during the years in issue. Specifically, Mr.
Abbene belonged to the New York Thoroughbred Breeder's
Association, the Professional Horseman's Association of Long
Island, and the Nassau-Suffolk Horseman's Association.3
Petitioners' daughter, Elena, began riding horses during
1970, at the age of 3, following a 50-cent pony ride. Elena has
trained with the United States Equestrian Team since age 15 and
is a 1989 Olympic Bronze Medalist.4 Petitioners spent $30,000 to
1 Mr. Abbene was employed with Pride Solvents for 21 years
from 1974 until 1995.
2 Mr. Abbene was born on Jan. 17, 1941.
3 Mr. Abbene served as the director of the Nassau-Suffolk
Horseman's Association for approximately 10 years from 1984 to
1994.
4 The parties stipulated that Elena "is a 1989 Olympic bronze
medalist." The record, however, also contains a business card on
which it is advertised that Elena is "a 1989 U.S. Olympic
Festival Bronze Medal Winner". Whether Elena participated in
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