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leasing it. This first breeding produced VT Kartel. She bred
Borissa a second time in 1991. This breeding, which apparently
also was connected with petitioner’s payment of the $5,000
breeding fee,9 produced Bogaz on May 19, 1991.10 She bred Borissa
a third time between July 7 and September 30, 1997, in the sense
that she paid a $3,000 breeding fee to the Bishop Lane Farm to
board, care for, and breed (including possibly by artificial
insemination) Borissa with a named stallion.11 This breeding
produced the referenced horse that was stillborn in 1998. She
then bred Borissa a fourth and final time in 2000. This final
breeding produced Censuous in 2001.
Petitioner continues to own Borissa, and she keeps it at the
Falling Water Way property. As of the time of petitioner’s
trial, Borissa’s fair market value was not more than $20,000.
Borissa is the only horse that petitioner has bred since 1989,
9 Although the contract underlying the $5,000 breeding fee
refers only to GoKart, and the stallion that helped produce Bogaz
was not GoKart, petitioner deducted no other breeding fees from
1988 until 1997.
10 Although the record does not indicate the period of
gestation for a horse such as Borissa, we recognize that the
length of this pregnancy was 20 weeks at the most. Given that
the parties have stipulated that Bogaz was the product of a 1991
breeding of Borissa and that the record establishes that Bogaz
was foaled on May 19, 1991, we find the relevant dates of this
pregnancy accordingly.
11 Petitioner also paid as to this breeding a $250 fee for
the transportation of semen. She deducted the total breeding fee
of $3,250 ($3,000 + $250) for 1997.
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