Harvey J. Davis and Patricia A. Davis - Page 11





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          Splendante in 1990, and a filly, De Lovelt, in 1991.  That's                
          Amore has produced no other offspring.                                      
               In 1997, petitioners acquired an Arabian stallion, HB                  
          Canadian Dsign, for $4,000.  Petitioners have shown HB Canadian             
          Dsign.                                                                      
               Six of petitioners’ nine horses--Brigitta La Brisa,                    
          Vendalita, That's Amore, Splendante, Brilliant, and Spanish                 
          Ballerina--were sired by one of two stallions that McDannald                
          imported from Spain and that he used in his breeding program.               
               4.   Improvements to Petitioners’ Residence for Use in the             
                    Horse Activity                                                    
               In 1990, petitioners’ residence was appraised at $65,000.              
          From 1990 to 1994, petitioners made improvements to their                   
          residential property to accommodate their Arabian horse activity.           
          They built a barn to store hay and equipment; a five-stall stable           
          with a tack room, workshop, and storage area for hay and a horse            
          trailer; a 50- by 100-foot arena; and a corral.  During that                
          time, they also acquired equipment such as a horse trailer and a            
          used pickup truck.  The improvements cost about $23,000.                    
          Petitioner planned and built most of the farm improvements                  
          himself.  He built the barn for the horses by himself in 1990.              
          He built the stable for the horses in 1990.  He did not do the              
          concrete work or build the structure or roof of the stable, but             
          he installed the flooring and the siding and built the stalls and           
          tack room.                                                                  





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