- 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