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the following gain or loss on the sale of those three horses:
Horses Gain or (Loss)
Northern Crush ($2,578)
Tarport Reactor (885)
Yankee Bardot $1,055
For each of the taxable years 1986 through 1998, Kildare
Timmy, which used a taxable year ending December 31, timely filed
Form 1065, U.S. Partnership Return of Income (partnership re-
turn), which Mr. Ramsburg signed as a general partner. Kildare
Timmy employed Keller Bruner to prepare those returns. In
preparing those returns, Dawson Grove and Brian Rippeon (Mr.
Rippeon), who worked for Keller Bruner, relied on information and
representations that Mr. Ramsburg and/or Mr. Stottlemeyer pro-
vided to them.
The respective partnership returns that Kildare Timmy filed
for the years 1986 through 1998, including certain schedules
included as part of those returns, showed, inter alia, the
following with respect to Kildare Timmy and with respect to Mr.
Ramsburg and Mr. Stottlemeyer:
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