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Silent Reign, that her adjusted basis in Silent Reign was $161
($3,500 purchase price less $3,339 of claimed deprecation), and
that she was entitled to recognize a $161 ordinary loss on this
sale. The parties do not dispute that petitioner is entitled to
deduct this reported loss as reported.
Petitioner continues to keep Silent Reign at the Falling
Water Way property. Petitioner’s 1997 through 2002 Federal
income tax returns do not specifically report her receipt of any
compensation for this service.
E. Borissa
Borissa is a purebred Arabian Polish mare that was foaled on
February 24, 1982, and that is or was registered with the Arabian
Horse Registry of America, Inc., as purebred Arabian horse No.
0268206. Its parents are Borexpo and Psyche, neither of which at
the time of Borissa’s registration was registered with the
Arabian Horse Registry of America, Inc., and the lineage of which
included no other horse that was then so registered.
Petitioner “leased” Borissa in 1989 for $1,000 in order to
avail herself of her continued right to breed mares in exchange
for the $5,000 breeding fee mentioned above, and she purchased
Borissa in 1990 for $2,500.8 Petitioner has bred Borissa a total
of four times. She first bred Borissa in 1990 while she was
8 The record does not elaborate on this lease or otherwise
allow us to discern its terms.
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