Louis A. Filios and Estate of Emma L. Filios, Deceased, Louis A. Filios, Executor - Page 8

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          name of the horse, its year of birth, its sire and dam, when                 
          petitioner acquired it and from whom, the purchase price, when               
          petitioner disposed of the horse, and the name of the party                  
          acquiring the horse.  Some index cards showed whether the horse              
          had a jockey certificate number, which the horse needed in order             
          to be eligible to race.  Kuta prepared the index cards in part to            
          show Kida which horses were depreciable and which were home-bred.            
               From 1974 to 1996 (excluding 1994), Kuta prepared yearly                
          breeding schedules for petitioner's mares.  These schedules                  
          generally included the name of each mare available for breeding,             
          the name of the stallion to which it was being bred, and the                 
          breeding fee.  If the mare was still carrying a foal from the                
          prior year's breeding, the schedule gave the name of the                     
          stallion.  Kuta prepared the breeding schedules to ensure that               
          she had properly registered the foals and paid breeding fees and             
          to determine whether a refund was due.                                       
               From about 1986 to 1997 (excluding 1994), Kuta kept annual              
          records which identified the location of most of petitioner's                
          horses each month and whether petitioner disposed of the horse               
          during the year.  Kuta kept these records to ensure that                     
          petitioner was billed correctly.                                             
               Petitioner never conducted any written economic or business             
          studies, prepared a written business plan or budget for his horse            
          racing and breeding activity, or hired any consultants to help               
          him make his horse racing and breeding activity profitable.                  

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