- 20 - because of their bankruptcy. Respondent also questions petitioners' intention to build the barn, arguing that, as petitioners had enough funds to spend on horse purchases and stud fees to produce half Arabians, petitioners were financially able to build the barn. As to respondent's argument that petitioners did not attempt to make changes in their operating methods and to reduce costs in order to improve the profitability of their horse activity, we disagree. Petitioners planned to begin horse boarding, horse training, teaching classes in connection with Farrier College, and operating a tack shop to sell equipment. Petitioners hired a contractor to build a 32-stall horse barn on their farm, which would have served both as a stable for the horses and as a location for the tack shop. When the contractor went bankrupt, petitioners built smaller barns to reduce the cost of boarding some of their horses. Finally, during the years in issue, petitioners attempted to sell horses but received offers that they considered too low. As to whether petitioners could have increased the profitability of their horse activity by selling some or all of their unproductive animals, we cannot conclude on this record that any of the animals were "unproductive". Mrs. Phillips, for example, testified that one gelding was used for Special OlympicsPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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