- 5 -
Year Mr. Perry Ms. Hofer Total
1986 $56,140 $40,608 $96,748
1987 52,014 39,910 91,924
1988 52,485 43,064 95,549
1989 55,167 43,358 98,525
1990 61,487 45,562 107,049
1991 56,905 48,653 105,558
Mr. Perry retired from General Motors in 1995. At the
time of trial, Ms. Hofer was on dependent care leave and
did not wish to return to work.
At the time they were married, petitioners planned
to acquire a farm and raise horses. Before implementing
this plan, petitioners had at least one conversation with
Mr. John Adkins, who had extensive experience breeding
Tennessee Walking Horses. Based on their discussions with
Mr. Adkins and their prior experience, petitioners decided
to acquire and develop a breeding stock of registered
Tennessee Walking Horses. Petitioners knew that the
undertaking would require a substantial outlay of cash and
that there was a significant likelihood of losses during
the early stages. However, petitioners did not have a
formal business plan or income projection at the time they
began the undertaking. Petitioners believed that they
could create a self-sustaining breeding operation by
acquiring and developing sufficient real estate, planting
appropriate crops, and acquiring attractive horses. At the
time they began their horse-related operation, petitioners
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