- 26 - (farm activity was operated for profit despite the fact that the taxpayer and his children used it for vacations). Thus, based on the entire record we find that petitioners operated Flying H with an intent to make a profit, and therefore the losses incurred during the years in issue are fully deductible. Issue 3. Whether Petitioners' Polo Sales Activity Known as Bendabout Polo Sales & Management Co. Was an Activity Engaged in For Profit Bendabout Polo Sales & Management Co. Bendabout Polo Sales and Management Co, or BPS, is a partnership, of which petitioner owns 75 percent and S.K. Johnston, petitioner's son, owns 25 percent. BPS began operations in 1986 as a polo horse sales business. BPS' sales were primarily conducted in southern Florida, while the polo pony training operations were conducted at Bendabout in Tennessee and Flying H in Wyoming. Petitioner is a longtime amateur polo player and served as president of the U.S. Polo Association from 1980 to 1984 and chairman from 1984 to 1988. Petitioner retired from playing polo in 1989, and the parties stipulated that he did not ride any of BPS' polo ponies during the years in issue. Petitioner has developed many contacts in the polo community worldwide. Based on his knowledge of polo and his contacts with people involved in the sport, petitioner thought there would be a profitable market for selling polo ponies. Respondent concedesPage: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
Last modified: May 25, 2011