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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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