S.K. Johnston, III and Julie N. Boyle f.k.a. Julie N. Johnston, et al. - Page 5

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            and S.K. Johnston, his son, owns 25 percent.  The sales aspect of                         
            BPS was primarily conducted in southern Florida, while the polo                           
            pony training operations were conducted at Bendabout in Tennessee                         
            and Flying H in Wyoming.  The fourth activity is GJ Stables (GJ                           
            or the stables), a steeplechase horse training business conducted                         
            by Gillian Johnston on 35 acres located at Bendabout.                                     
                  The parties have stipulated that petitioners carried on each                        
            of these four activities in a businesslike manner and maintained                          
            complete and accurate books and records.  With respect to all                             
            four activities, the parties further stipulated that none of the                          
            expenses in issue constitute personal living, or family expenses,                         
            and that each activity keeps adequate accounting records                                  
            separating business from personal expenses, including gas and                             
            utilities.                                                                                
                  Petitioner                                                                          
                  At the time of trial, petitioner was 62 years of age and                            
            resided in Atlanta, Georgia.  He has lived at Bendabout his                               
            entire life, including the years in issue.  Petitioner is married                         
            to Gillian Johnston and they have five children.  During the                              
            years in issue, two of the children were minors who lived with                            
            them at Bendabout. Bendabout has been in the Johnston family                              
            since the 1830's. Petitioner inherited the farm from his father                           
            in 1985.                                                                                  
                  Petitioner is a successful business executive.  He currently                        
            serves as the president and chief operating officer of publicly                           



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