- 5 - 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 publiclyPage: 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