- 4 -
$50,000 of their own funds each year to cover Elena's training
and competition costs.
During 1975, petitioners purchased the 1� acre property
located at 6 Tide Mill Road (the property), and they have
maintained the property as their primary residence every year
since then. At the time it was purchased, there was a 13-room
house on the property, but there was no barn. Sometime during
either 1976 or 1977, petitioners built a barn on the property, at
a cost of $2,600. Two years later petitioners built a second
barn on the property, to match the first, also at a cost of
$2,600. During 1988, petitioners built a third barn on the
property, at a cost of $49,870, after one of the original barns
was destroyed by fire.5
During the years subsequent to the purchase of the property,
Mr. Abbene purchased the following horses and equipment,
ownership and title to which are in his name individually, for
use in connection with his horse-related activities:
Horses
Purchase Year Year Year
Name Type of Horse Price Purchased1 Born Died
Country Girl Female Welsh pony $750 1976/1977 1959 1995
Nakita Female Shire 2,200 1976/1977 1970/1971 2
4(...continued)
official Olympic competition during 1989 or in an "Olympic
Festival", however, is immaterial to our analysis.
5 The record does not disclose which of the two original barns
was destroyed by fire.
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