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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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