Eugene J. Phillips and Barbara A. Phillips - Page 20

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          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 Olympics           








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