Barry S. and Yvonne C. Hillman - Page 8

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          easy-to-ride horse.  Petitioners sold Chicardo on June 1, 1995,              
          for $1,800.                                                                  
               Petitioners purchased Ashley, a 2-year-old filly, in 1984               
          for $2,500.  Petitioners claimed Ashley for their show horse                 
          activity in 1994 only.  Ashley participated in two horse shows in            
          1990, for which neither the prize money nor expenses are known.              
          Morgan mares generally begin to be bred at about 4 years of age              
          and can produce one foal a year.  Ashley miscarried three foals              
          in 4 years.  Ashley never produced a live foal, and had a history            
          of uterine infections.  On October 5, 1994, petitioners donated              
          Ashley to Ohio State University, College of Veterinary Medicine.             
          Ashley had a uterine infection at the time of the donation.  Dr.             
          Hillman executed a euthanasia authorization in connection with               
          the donation, which was required by Ohio State University for all            
          such donations.  After digestive problems were discovered, Ashley            
          was euthanized on December 23, 1994.                                         
               On their 1994 return, petitioners claimed a deduction for a             
          noncash charitable contribution with respect to Ashley in the                
          amount of $4,800.  Petitioners’ return reported that Ohio State              
          University determined Ashley’s fair market value.  However, Ohio             
          State University does not provide appraisals for gifts of                    
          property and did not do so in Ashley’s case.                                 
               None of petitioners’ horses participated in horse shows in              
          1993.  Aside from the $125 earned by Ben Hur, petitioners did not            

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