Louis A. Filios and Estate of Emma L. Filios, Deceased, Louis A. Filios, Executor - Page 4

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          D.   Eugene Kida                                                             
               Eugene Kida (Kida) worked for Westfield Gage from 1984 to               
          1995.  He is a certified public accountant (C.P.A.) and has a                
          master's degree in Business Administration.                                  
               Kida prepared petitioners' personal income tax returns while            
          he worked for Westfield Gage.  To prepare petitioners' income tax            
          returns, Kida reviewed Kuta's horse racing and breeding records.             
          Kida reviewed petitioners' tax returns with petitioner each year.            
          E.   Petitioner's Horse Racing and Breeding Activity                         
               1.   General                                                            
               Petitioner bought his first thoroughbred horse in 1955.                 
          Petitioner kept a horse 3 or 4 years after it was born so he                 
          could decide whether he thought it would race successfully.                  
          Petitioner's best horses generally ran in races paying purses                
          from $12,000 to $30,000.                                                     
               Petitioner never trained or stabled any of his horses at or             
          near his home in West Springfield.  He did not own a farm or any             
          equipment used in his horse activity.  Petitioner rode horses at             
          riding stables or riding schools near his home.  He and the                  
          members of his family did not ride his horses.                               
               2.   Horse Publications                                                 
               Petitioner subscribed to various horse industry publications            
          including The Blood Horse and Thoroughbred Record from 1959                  
          through the years in issue.  He read many horse racing and                   
          breeding books and magazines.  He also read The Blood Horse                  
          Stallion Register, which was published annually.  It contains                

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