S.K. Johnston, III and Julie N. Boyle f.k.a. Julie N. Johnston, et al. - Page 3

                                                - 3 -                                                 

                  After concessions by the parties, the issues for decision                           
            are: (1) Whether petitioners'3 farming activity known as                                  
            Bendabout Farm was an activity engaged in for profit under                                
            section 183 during the taxable years in issue.  We hold it was.                           
            (2) Whether petitioners' ranching activity known as Flying H                              
            Ranch was an activity engaged in for profit under section 183                             
            during the taxable years in issue.  We hold it was. (3) Whether                           
            petitioners' horse sales activity operated through a partnership                          
            known as Bendabout Polo Sales and Management was an activity                              
            engaged in for profit under section 183 during the taxable years                          
            in issue.  We hold it was. (4) Whether Gillian Johnston's horse                           
            training activity known as GJ Stables, conducted at Bendabout                             
            Farm, was an activity engaged in for profit under section 183                             
            during the taxable years in issue.  We hold it was.  (5) Whether                          
            $1,131,438 was the fair market value of a conservation easement,                          
            encumbering the Flying H Ranch donated by petitioners to the                              
            Nature Conservancy during 1989.  We hold it was.4                                         
                  Some of the facts have been stipulated and are so found.                            
            The stipulated facts and the accompanying exhibits are                                    
            incorporated into our findings by this reference.                                         


            3     Hereinafter, the term "petitioners" refers to S.K. Johnston,                        
            Jr. and Gillian Johnston, unless discussing BPS, where the term                           
            petitioners refers to S.K. Johnston, Jr. and Gillian Johnston and                         
            S.K. Johnston III and Julie N. Boyle, f.k.a. Julie N. Johnston.                           
            4     Due to our holding for petitioners on all five issues, we                           
            need not address whether petitioners are liable for additions to                          
            tax or accuracy-related penalties.                                                        



Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011