S.K. Johnston, III and Julie N. Boyle f.k.a. Julie N. Johnston, et al. - Page 17

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            was somewhat camouflaged by the polarization of the thoroughbred                          
            industry due to the fact that the upper-end of the market was                             
            controlled by Middle Eastern oil sheiks, who continued to pay top                         
            dollar for yearlings.  In the late 1980's, when the sheiks'                               
            demand for thoroughbreds declined, the yearling prices plummeted.                         
            As a result, both newcomers and old-line professional                                     
            thoroughbred farmers were faced with substantial losses.  In                              
            fact, it was during this time that many of the historically well-                         
            known and successful horse breeding farms went bankrupt.                                  
                  Respondent further argues that the Johnstons received                               
            personal pleasure and recreational benefits from operating                                
            Bendabout, which is persuasive evidence that the activity was not                         
            engaged in for profit.  Respondent notes that during the years in                         
            issue the Johnstons lived on the farm, and petitioner spent time                          
            there hunting and fishing.  Moreover, respondent focuses on the                           
            fact that during the years in issue petitioner held a dove hunt                           
            and fish fry at Bendabout to entertain his Coca-Cola colleagues.                          
            We note, however, that the parties stipulated that none of the                            
            losses claimed by petitioners with respect to their farm activity                         
            constituted personal, living, or family expenses.  Moreover, at                           
            trial petitioner credibly testified that he paid for the cost of                          
            the annual dove hunt and fish fry out of his pocket.                                      
                  Respondent contends that because of petitioners' financial                          
            status the losses from Bendabout actually generated a tax                                 
            benefit.  Given petitioner's substantial other income, it is true                         



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