S.K. Johnston, III and Julie N. Boyle f.k.a. Julie N. Johnston, et al. - Page 26

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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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