Elizabeth Giles - Page 50

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          veterinary services, and 4) $2,135 and $2,450 for farrier                   
          (blacksmith) services.                                                      
               We also believe that it is evident that petitioner gains               
          personal pleasure from the horse activity.  She testified that              
          she was compelled to buy her first horse because she had been               
          away from horses for awhile.  She also admittedly rode her horses           
          during the relevant years in the wilds of the undeveloped (and              
          most likely scenic) 11.53 acres of the Gavilan Hills property.              
          To our minds, such riding on that property was more conducive to            
          pleasure than to pure training, the latter of which most likely             
          could have been done in the arena that petitioner had purchased             
          (or built) approximately 1 year before purchasing the Gavilan               
          Hills property.  We also note that petitioner throughout her                
          testimony repeatedly referred to her horses as her “babies” and             
          opted not to dispose of her “babies” even when they were aged,              
          unable to breed, expensive to maintain, and/or unprofitable.28              
               This factor favors respondent.                                         
          10.   Additional Factor                                                     
               Petitioner did not on any of her 1988 through 2002 Schedules           
          C deduct interest or taxes paid as to the Falling Water Way                 
          property and the Gavilan Hills property.  We consider this fact             


               28 For example, she has kept Feyras Raehele at the Falling             
          Water Way property but has not bred it since 1988, and she has              
          kept Silent Reign at that property even though she sold it to her           
          daughter in 1997.                                                           





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