Elizabeth Giles - Page 11

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               C.  Kart Blanche                                                       
               Kart Blanche is a purebred Arabian mare that was foaled on             
          April 21, 1989, from the just-mentioned breeding of Feyras                  
          Raehele.  Kart Blanche is or was registered with the Arabian                
          Horse Registry of America, Inc., as purebred Arabian horse No.              
          0428977.  Its parents are GoKart and Feyras Raehele, both of                
          which at the time of Kart Blanche’s registration were registered            
          with the Arabian Horse Registry of America, Inc., and had lineage           
          that included some other horses that were then so registered.               
          Petitioner has never bred Kart Blanche.  Petitioner showed Kart             
          Blanche from 1990 to 2000 at 34 competitions, and Kart Blanche              
          won 3 of those competitions.                                                
               Petitioner continues to own Kart Blanche, and its fair                 
          market value as of the time of her trial was not more than                  
          $35,000.  The record does not indicate the amount of income, if             
          any, that petitioner has realized from her ownership of Kart                
          Blanche.                                                                    
               D.  Silent Reign                                                       
               Petitioner purchased Silent Reign in 1989 for $3,500.                  
          Silent Reign has never been bred, shown, or otherwise used for              
          profit in the horse activity.  Petitioner reported on her 1997              
          Federal income tax return that on December 31, 1997, she sold               
          Silent Reign to her daughter for no consideration.  She reported            
          on that return that she had claimed $3,339 of depreciation on               






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