Eugene J. Phillips and Barbara A. Phillips - Page 21

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          children and that other geldings were used for                              
          bridleless/saddleless teams.  Additionally, geldings were helpful           
          in entertaining children of potential buyers.                               
               We disagree with respondent's contention that petitioners              
          increased the costs of maintaining their herd.  Mrs. Phillips               
          testified that they attempted to sell some horses but that they             
          received unacceptably low offers.  As to the purchase of two                
          horses for $1,300 and the outlay of $6,500 in stud fees,                    
          respondent essentially argues that petitioners exercised bad                
          business judgment as to those transactions.  We do not conclude             
          that the expenses were either inconsistent with a profit motive             
          or unnecessary and extravagant.                                             
               Furthermore, we disagree with respondent's contention that             
          petitioners' advertising efforts at horse conventions were                  
          ineffectual.  As we have stated above, we believe that, during              
          the years in issue, petitioners were merely sustaining their                
          horse activity until Mrs. Phillips could proceed with the                   
          expansion plans once she recovered.  Although petitioners were              
          unable to increase substantially the level of horse breeding                
          during the bankruptcy period, we view their attendance at horse             
          conventions as efforts to sustain both their name and their                 
          farm's name in the Arabian horse industry.  Accordingly, we                 









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