S.K. Johnston, III and Julie N. Boyle f.k.a. Julie N. Johnston, et al. - Page 27

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            that petitioner's contacts in the polo community were helpful in                          
            selling horses.                                                                           
                  The parties stipulated that BPS employed expert advisers and                        
            competent and qualified persons to carry on its horse sales                               
            activities.  In 1986, petitioners hired Jeff Atkinson (Atkinson),                         
            a seven-goal professional polo player and professional horse                              
            trainer, to run BPS.  Atkinson's duties included training horses,                         
            supervising grooms, organizing the shipping of the horses, and                            
            selling horses.  Prior to joining BPS, Atkinson had been in the                           
            polo sales business for many years.  During that time, his sales                          
            business accounted for over 60 percent of his income, and he had                          
            sold more than 100 polo ponies.                                                           
                  The initial strategy of BPS was to purchase horses in                               
            Argentina because of the country's reputation in the polo                                 
            community for producing high-quality horses.  Some of these                               
            horses would be ready to play with little training and could be                           
            resold immediately.  Petitioner and Atkinson thought that BPS                             
            would be able to double its money on those horses because                                 
            petitioner had a source from which BPS could acquire the horses                           
            cheaply.  BPS also intended to develop a brood mare string from                           
            the Argentinean horses, breed the mares, and train and sell the                           
            foals as polo ponies.  During the years at issue, BPS generally                           
            had about 12 to 24 horses in training and for sale at any one                             
            time.                                                                                     





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