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Operation of Blue Ribbon
Sometime before January 24, 1989, Capital Cities/ABC, Inc.
(ABC), approached Mr. Abbene about the possibility of using King
Lion in the filming of an episode of one of its daytime dramas,
"All My Children" (AMC). On January 27, 1989, Mr. Abbene
incorporated Blue Ribbon in order to take advantage of the
opportunity to rent his horse to ABC, which dealt only with
corporations.
Mr. Abbene is Blue Ribbon's sole shareholder. Blue Ribbon
conducts its operations on the property using Mr. Abbene's horses
and equipment.8 Mr. Abbene never transferred ownership of the
horses and equipment or the property to Blue Ribbon. Blue Ribbon
never paid petitioners any rent or income for the use of the
property or the horses and equipment in its operations.
On January 24, 1989, 3 days before Blue Ribbon's
incorporation, Mr. Abbene entered into an agreement with ABC, on
Blue Ribbon's behalf, to rent certain horse-riding equipment to
ABC for $10,400. On February 8, 1989, Blue Ribbon entered into a
second agreement with ABC to rent King Lion to ABC for $3,432.
ABC rented the horse and the riding equipment for use in the
filming of an episode of AMC during February 1989. During
8 In addition to the horses listed supra p. 4, Mr. Abbene
acquired Queenie, a female Shire, during either 1990 or 1991.
Queenie was not used by Blue Ribbon for any income-producing
activity.
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Last modified: May 25, 2011