Harvey J. Davis and Patricia A. Davis - Page 6

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          B.   Petitioners’ Arabian Horse Activity                                    
               1.   Petitioners’ Early Involvement With Horses                        
               Petitioner owned a half Arabian gelding in his youth.  He              
          trained the horse and entered it in calf roping exhibitions from            
          1942 to 1954.                                                               
               In 1971, petitioners attended an Arabian horse show in                 
          Albuquerque, New Mexico.  Petitioner had never seen a purebred              
          Arabian horse and was very impressed.  Petitioners ascertained              
          the price of some of the horses at the show.  They also visited             
          several Arabian horse farms and looked at the facilities.  They             
          wanted to own and raise Arabian horses someday.                             
               Also in 1971, petitioners bought for pleasure a purebred               
          Arabian gelding named Alasana.  Mrs. Davis and petitioners’                 
          children learned to ride Alasana, and the children showed him in            
          4-H shows.  Alasana died in 1985.                                           
               In 1990, Mrs. Davis visited Mountain View Arabians, an                 
          Arabian horse farm in Colorado, that was owned by a woman in her            
          seventies.  The owner had raised Arabian horses all her life and            
          was still showing horses.  In 1990, petitioners visited the                 
          McDannald Arabian farm, owned by Paul McDannald (McDannald).                
          McDannald trains, shows, and breeds horses, and teaches others              
          how to show horses.  McDannald is a well-known horse trainer.               
               In 1990, petitioners visited two Arabian horse farms they              
          had visited in 1971.  They preferred the McDannald Arabian farm             

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