Martin and Marion Abbene - Page 8

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            that King Lion won during 1990, placing second at the Hamptons                               
            Classic, King Lion won no prize moneys during the years in issue.                            
            Mr. Abbene kept no formal ledger of King Lion's winnings.  The                               
            remaining horses were generally shown for ribbons only.  Country                             
            Girl, Toast of the Town, Meadow Silk Spirit, and Spectacular                                 
            Rhythm, however, were not shown during the years in issue.  Magic                            
            Moment was injured and had to be destroyed during 1991.10                                    
                  Blue Ribbon used Country Girl, Toast of the Town, and Meadow                           
            Silk Spirt for riding lessons.  During the years in issue, Elena                             
            provided, on behalf of Blue Ribbon, riding lessons to four                                   
            individuals, some of whom went on to successfully compete.  Blue                             
            Ribbon charged $30 for a half-hour lesson and $50 for an hour                                
            lesson.  Mr. Abbene maintained neither a log of the riding                                   
            lessons given by Elena nor a formal ledger of the income derived                             
            from the provision of riding lessons during the years in issue.                              






            9(...continued)                                                                              
            stipulated that King Lion was the only horse shown for prize                                 
            moneys.  Consistent with the stipulation of facts, respondent                                
            requested the Court to find that King Lion was the only horse                                
            shown for prize moneys during the years in issue.  As petitioners                            
            made no objection to the requested finding of fact, we shall                                 
            treat the stipulation of facts as a conclusive admission by the                              
            parties.  Rule 91(e).                                                                        
            10    The record does not disclose the year in which Magic Moment                            
            suffered injury.                                                                             




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