Eugene J. Phillips and Barbara A. Phillips - Page 15

                                       - 15 -                                         
          petitioners maintained a business plan, which was to expand their           
          horse activity so that it could, among other things, support Mrs.           
          Phillips in the event that Mr. Phillips predeceased her.  The               
          business plan was evidenced by their actions:  Petitioners                  
          contracted to build a barn and a tack shop for their horse                  
          activity, bred Bella Joya to produce foals, and registered many             
          of their Arabians with the International Arabian Horse                      
          Association.                                                                
               During the years in issue, however, numerous circumstances             
          beyond their control prevented petitioners from proceeding with             
          their business expansion plan.  Mrs. Phillips encountered several           
          health problems that prevented her from pursuing petitioners'               
          horse activity to the fullest.  Bella Joya's first foal, which              
          would likely have garnered a significant amount of income, had to           
          be put to sleep.  The barn was not completed before Mrs.                    
          Phillips' automobile accident, so petitioners had to delay                  
          construction of the barn and tack shop.  Consequently,                      
          petitioners continued to sustain boarding expenses and lost                 
          potential boarding income.  We consider also the fact that                  
          petitioners were making payments under chapter 13 bankruptcy.  We           
          believe that, during the years in issue, petitioners did all that           
          they could to sustain their horse activity until Mrs. Phillips              
          recovered.                                                                  








Page:  Previous  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  Next

Last modified: May 25, 2011