Jane Freed - Page 3

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          herd consisted of three breeding horses and eight racing horses.            
          Petitioner’s breeding herd is stabled at McMahon of Saratoga                
          Thoroughbreds Farm (McMahon Farm).  Petitioner’s racing herd is             
          boarded at various tracks where they race, which is standard                
          practice for racing thoroughbreds.  The horses race exclusively             
          in New York State.  She visits her horses in person only three to           
          four times per year.  She most often watches her horses race via            
          closed circuit simulcast in New Jersey.  She never had any of her           
          thoroughbred horses appraised.                                              
               Petitioner’s educational background consists of a bachelor’s           
          degree in anthropology that she received from Monmouth College in           
          1981.  Her employment history consists of a lab technician’s                
          position for an archeologist as well as a position as an                    
          instructor at an archeology field school between 1981 and 1983.             
               Petitioner is the beneficiary of three trusts holding assets           
          with a total value of approximately $6 million.  The trusts were            
          funded by petitioner’s inheritance from her mother.   Petitioner            
          derives her primary income from dividends and interest received             
          from the trusts.  From 1985 through 1996, she received over $3.2            
          million of income from the trusts–-over $200,000 in 1996 alone.             
          Petitioner did not make a profit from her thoroughbred horse                
          breeding and racing activities in any year between 1982 and 1996.           
          Her losses during that time totaled over $1.1 million.                      








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