Louis A. Filios and Estate of Emma L. Filios, Deceased, Louis A. Filios, Executor - Page 6

                                        - 6 -                                          
               Petitioner went to England, France, and Germany in 1977 on a            
          tour of breeding farms, race tracks, and training centers                    
          sponsored by Cornell University.  Petitioner also toured similar             
          facilities in Ireland on a date not specified in the record.  He             
          took courses about horses at Cornell University in 1985, 1986,               
          and 1990, and stud manager’s courses in 1964 and 1970.                       
               From 1961 to 1996, petitioner gave away 124 horses that were            
          not performing well because it cost too much to maintain them.               
               5.   Records and Reports                                                
               Westfield Gage (not petitioner) paid Kuta to keep the                   
          records for petitioner's horse racing and breeding activity from             
          1955 through the years at issue.  She spent 10 to 15 percent of              
          her time working on the horse racing and breeding activity.  Some            
          of that time was at the end of each year when she gathered                   
          information for petitioner's tax returns.  Kuta decided which                
          records of the horse racing and breeding activity to keep and how            
          to keep them.                                                                
               Petitioner had a separate bank account for his horse racing             
          and breeding activity from 1963 through the years in issue.  Kuta            
          kept copies of canceled checks, check registers, invoices, and               
          correspondence that related to the horse racing and breeding                 
               At the end of each year, Kuta prepared summaries from race              
          track statements to ensure that the Forms 1099 issued by the                 
          racetracks were accurate.  She also used race track statements to            

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011