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Petitioner purchased Feyras Raehele in January 1988 for
$11,000, and she showed it during that year in at least one
competition.7 She also during 1988 bred Feyras Raehele because
the opportunity arose for her to pay $5,000 to breed it and any
other mare an unlimited number of times with a stallion named
GoKart that had previously commanded a breeding fee of $15,000.
Petitioner considered this opportunity to be a good chance for
her to breed Feyras Raehele with a respectable stallion at a
significantly reduced fee. She paid the $5,000 breeding fee in
1988, and she deducted this payment as an expense for 1988.
Petitioner’s 1988 breeding of Feyras Raehele with GoKart produced
Kart Blanche. This was the only time that petitioner has bred
Feyras Raehele, and it was the only time that petitioner has bred
a horse other than Borissa.
Petitioner continues to own Feyras Raehele, and she keeps it
at the Falling Water Way property. As of the time of
petitioner’s trial, the fair market value of Feyras Raehele was
not more than $10,000. The record does not indicate the amount
of income, if any, that petitioner has realized from her
ownership of Feyras Raehele.
7 The record does not contain information on any show in
which Feyras Raehele has competed, or whether Feyras Raehele has
competed in more than one show.
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Last modified: May 25, 2011