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(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 concedes
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