S.K. Johnston, III and Julie N. Boyle f.k.a. Julie N. Johnston, et al. - Page 8

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                        GJ Stables/steeplechase                   35 acres                            
                        Horse breeding/thoroughbred               86 acres                            
                        Woods and roads                     1,022 acres                               
                  In the early 1980's, petitioner began taking over the farm                          
            operations from his father, who died in 1985.  Petitioner, who                            
            grew up around horses and followed the horse breeding industry,                           
            has acquired knowledge about horse activities, including                                  
            thoroughbred breeding.                                                                    
                  From the early to mid-1980's, the thoroughbred industry was                         
            healthy, growing, and considered to be a good investment among                            
            professionals in that field.  Given the robustness of the                                 
            thoroughbred industry, petitioner thought that operating a                                
            thoroughbred breeding business at Bendabout could be very                                 
            lucrative.  Under the management of petitioner's father,                                  
            Bendabout had been used to range cattle.  Petitioner, however,                            
            believed that the pastures, barns, and other physical facilities                          
            at Bendabout could be used most efficiently for thoroughbred                              
            breeding and boarding operations, and that using the farm's                               
            facilities primarily for such operations would be more profitable                         
            than the cattle operations.                                                               
                  It takes a number of years to build a viable horse breeding                         
            operation.  The parties agree that the minimum startup period in                          
            the thoroughbred breeding business is 7 years.  It takes at least                         
            2 years from the time of purchasing a mare to realize any income                          
            from the investment, because there is an 11-month gestation                               
            period, and it takes another year to raise the foal to a                                  



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