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also held future income interests, as discussed below, in TF
Silent Reign in 1999, and in TF Silent Reign and Mon Reve in
2000.
At the beginning of 2001, petitioner owned Feyras Raehele,
Kart Blanche, Borissa, and Bogaz and continued to hold future
income interests in TF Silent Reign and Mon Reve. During 2001,
petitioner acquired Censuous by breeding. In December 2001,
petitioner sold Bogaz for $20,000.
Following is a description of petitioner’s horses and
related breeding activity.
a. Feyras Raehele and Kart Blanche
In 1984, petitioner purchased Feyras Raehele, an Arabian
mare4 foaled5 on May 19, 1979. During 1988, petitioner bred
Feyras Raehele. On April 21, 1989, Feyras Raehele produced a
filly,6 Kart Blanche.
b. Borissa, Bogaz, and Censuous
In 1989, petitioner leased Borissa, a mare foaled in 1982,
from Raymond Mazzei of Furioso Farm for breeding purposes. On
4 A “mare” is a female horse of reproductive age.
5 “Foaled” is synonymous with “born”. A “foal” is a baby
horse of either sex. “In foal” indicates that a mare is
pregnant. The gestation period for an Arabian horse is typically
11 months, but can be anywhere from 10 to 12 months.
6 A “filly” is a female horse 3 years old or younger.
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