Elizabeth Giles - Page 23

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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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