- 27 - 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.Page: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
Last modified: May 25, 2011