- 2 - FINDINGS OF FACT Raymond Murphy has been a veterinarian specializing in horses for forty years. He also became a real estate developer, and a few of the deductions originally contested in this case come from that business. But the bulk of this case, and Murphy’s great pleasure, comes from breeding, raising, and trading thoroughbred horses. Although Murphy has owned a stableful over the years, only three horses figure in this case: Hamseh, Desert Spice, and On the Piste. All three are broodmares, and all came to Murphy from what he described as his “wheeling and dealing” and “whipping and dipping” with Philip DeVere Hunt of Tipperary, Ireland, a fellow breeder whom Murphy has long known. Murphy bought Hamseh and Desert Spice from Hunt in 1994. Hamseh cost him $600,000, which he financed in part with a promissory note for $425,000 in Hunt’s favor. Interest on this note accrued at a rate of ten percent per annum on any unpaid balance, and the note required interest payments in August 1995 and August 1996, and then all remaining principal and interest by December 31, 1996. The note stated that “all payments shall be first applied to interest and the balance to principal.” Desert Spice cost Murphy $385,000. He financed $379,000 of the total price with a promissory note. Like the note for Hamseh, this note also had a specific repayment schedule: (1) $40,000 of principal in May 1995; (2) interest at ten percentPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011