- 29 - had not been sold to recuperate, and start training another string of horses for the summer selling season. This string was not of the same quality as the Florida horses, because the level of play at the summer selling clubs was not as high, and second- tier purchasers were not willing to spend as much money. Petitioner and S.K. Johnston would meet with Atkinson at the beginning of each year to discuss the selling strategy during the upcoming season. During this time the three of them would decide which clubs and tournaments Atkinson would travel to based on the caliber of clientele attending. Atkinson knew the level of players at the various clubs and tournaments and what the purchasers at those events would be willing to spend. Based on that information, petitioner, S.K. Johnston, and Atkinson decided which ponies Atkinson would take with him to Florida. They would also prepare a budget for the upcoming sales season. During the years at issue, BPS made additional income from an annual sponsorship fee that Coca-Cola Co. paid the partnership to put together a polo team to play in matches. BPS faced a history of losses. After losing its key employee, BPS sold off the remaining horses and in 1993 the partnership was dissolved. Discussion Once again, respondent points to a history of losses, petitioners use of such losses to offset other income, and thePage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
Last modified: May 25, 2011