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Petitioner maintained a library of horse-related reference
materials, including 15 books, 6 trade journals/periodicals, and
14 video sets. During the years in issue, petitioner spent 6 to
8 hours per month reading trade journals.
Petitioner had a Falling Water Arabians business card
listing the Falling Water Way address as the business address.
However, the business card was prepared in the late 1980s, and
the phone numbers are no longer correct.
Petitioner maintained a checking account with California
Bank & Trust in Moreno Valley, California, under the names
Elizabeth Giles and Falling Water Arabians. From December 16,
1998, to December 3, 2001, the account’s average daily balance
never exceeded $402. A $9 maintenance fee was deducted from the
account monthly. The only other withdrawal taken during this
period was $240 on April 13, 2000, the purpose of which was not
identified. As of April 17, 2001, the account had a negative
balance of -40 cents. The only deposit made before December 4,
2001, was $9, deposited on May 5, 2001, in order to restore a
positive account balance. On December 4, 2001, petitioner
deposited $20,000 received from the sale of Bogaz, as discussed
below.
During the years in issue, petitioner spent 4-1/2 to 6 hours
a day with the horses. In a typical day, petitioner fed,
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Last modified: May 25, 2011