- 17 - 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 truePage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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