Jane Freed - Page 5

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          because she felt the better weather and grass there gave her                
          horses a training advantage when the racing season began in New             
          York.                                                                       
               Richard Mahon (Mahon) is a CPA licensed in New Jersey.                 
          Petitioner has employed Mahon to perform record keeping for her             
          thoroughbred horse breeding and racing activities since                     
          approximately 1982, and he has many other clients who raise                 
          horses.  These records were distinct from petitioner’s personal             
          financial records.                                                          
               In 1996, Mahon prepared annual and semiannual Statements of            
          Income Collected and Expenses Paid for petitioner’s thoroughbred            
          horse breeding and racing activities.  Each statement included              
          results from the prior year for purposes of comparison.                     
               Mahon provided other services to petitioner in 1996 as well            
          as in previous years.  He prepared miscellaneous ledgers,                   
          maintained other records in connection with petitioner’s                    
          thoroughbred horse breeding and racing activities, and prepared             
          petitioner’s Federal and State income tax returns.  Petitioner              
          did not prepare nor did she have prepared balance sheets,                   
          financial projections, or budgets in connection with her                    
          thoroughbred horse breeding and racing activities for any year in           
          which she engaged in the activities.                                        









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