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and/or in reply to leading questions asked by her counsel during
direct examination. Portions of her testimony also were
inconsistent with other portions, with stipulated facts, and/or
with documentary evidence. We illustrate the inconsistencies in
petitioner’s testimony through seven examples. First, she
testified that she purchased her first horse, Feyras Raehele, in
1985. We find (and she has stipulated) that she purchased her
first horse, Feyras Raehele, in 1988. Second, she testified that
she purchased Feyras Raehele while she was going to dental
school. Per her own admission, she completed dental school in
1981, 7 years before the actual year in which she purchased
Feyras Raehele and 4 years before the year that she testified was
the year in which she purchased Feyras Raehele. Third, she
testified that she “contributed” Silent Reign to her daughter
under an agreement whereby her daughter would breed Silent Reign
and she and petitioner would split the profits. She reported on
her 1997 Federal income tax return that she sold Silent Reign to
her daughter during 1997 and that she was entitled to recognize a
$161 ordinary loss on this sale. Fourth, she testified that she
sold Bogaz in 2000 and that she purchased the Gavilan Hills
property in 1991 for $7,000. The record establishes that she
sold Bogaz in 2001 and that she purchased the Gavilan Hills
property in 1990 for $70,000. Fifth, she testified that during
the subject years she did all of the training of her horses. On
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