Richard L. and Marjorie A. Pitts - Page 4




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          raised, bred, and raced them.  The costs for the caring of                  
          petitioners’ horses at the Kerr farm were included as part of               
          petitioners’ wages.  Petitioners hired professional trainers for            
          the racing of the horses.  Their horses were racing at Los                  
          Alamitos, Golden Gate, and Bay Meadows racetracks.                          
               Petitioners left the Kerr farm in 1987 and moved back to               
          their house in Whittier with their horses.  Petitioner was                  
          employed at Lawyers Mutual Insurance Co., and Mr. Pitts,                    
          suffering from a muscle-wasting disease which required drug                 
          therapy, stayed home.                                                       
               Around 1988, petitioners decided that racing quarter horses            
          was too expensive.  The trainer’s fees were high, and the purses            
          were small.  Petitioner owned a thoroughbred with five other                
          people which had won $25,000 in a race in 1987.  Petitioners                
          decided to switch to thoroughbred horses because stakes races               
          (such as the Kentucky Derby) paid higher purses.  Petitioners               
          sold some of their quarter horses and started acquiring                     
          thoroughbreds.4                                                             
               Initially, petitioners acquired two thoroughbred mares and             
          Ding Dong Daddy, a thoroughbred stallion that came from good                
          blood lines.  Petitioners offered Ding Dong Daddy for stud.                 
          According to a promotional flyer that petitioners distributed,              
          Ding Dong Daddy had earned $24,964 in his first 2 years of                  
          racing.  The flyer also detailed the horse’s sire and female                

          4  Petitioners did retain one quarter horse that they raced,                
          and another that they bred.                                                 

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