S.K. Johnston, III and Julie N. Boyle f.k.a. Julie N. Johnston, et al. - Page 32

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           horse operation were a mere hobby, activity for pleasure, or a                             
           business founded solely for tax benefits, it would not seem                                
           petitioner would entirely abandon the operation."  Trafficante v.                          
           Commissioner, T.C. Memo. 1990-353.                                                         
                  Thus, based on the entire record we find that petitioners,                          
           through BPS, operated their horse sales activity with the intent                           
           to make a profit.  Accordingly, petitioners' related losses for                            
           the years in issue are deductible.                                                         
           Issue 4. Whether Gillian Johnston's Horse Training Activity Known                          
           as GJ Stables, Conducted at Bendabout Farm, Was an Activity                                
           Engaged in For Profit                                                                      
                  GJ Stables                                                                          
                  During the years in issue, Gillian Johnston, a licensed                             
           steeplechase horse trainer since 1964, operated a steeplechase                             
           training and racing activity known as GJ Stables out of a                                  
           converted cow barn and pasture on approximately 35 acres at                                
           Bendabout farm.  Gillian Johnston has had one assistant for at                             
           least 8 years.  Respondent stipulated that petitioners employed                            
           competent help to carry on the horse training and racing                                   
           activities of the stable.                                                                  
                  Unlike a breeding stable which makes money by selling                               
           horses, a racing stable such as GJ makes money primarily by                                
           racing its horses to win purses.  There is, however, always the                            
           possibility that a very successful racing horse may be purchased.                          
                  In operating the stable, Gillian Johnston consulted with                            
           recognized experts in the steeplechase business, including Dr.                             



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