Estate of Edward Brockenbrough, Deceased, Sharon Brockenbrough, and Suntrust Bank, Coexecutors, and Sharon Brockenbrough - Page 8

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          Bumgarner was a professional horse trainer who trained quarter              
          horses, produced rodeos, and was on the Georgia Rodeo Board.  He            
          was also a chaplain for the Rodeo Cowboys Association of America.           
          Roland was a quarter horse specialist.  Cashion was familiar with           
          the quarter horse, cattle, and rodeo businesses.  He rode quarter           
          horses in rodeos.  At the time of trial, Cashion managed a                  
          business of raising quarter horses and cattle.                              
               Mr. Brockenbrough thought petitioners could make a profit by           
          selling quarter horses because quarter horses are preferred by              
          rodeo riders and barrel racers, and they work well with cattle.             
          However, he believed that it would be several years before                  
          petitioners could make a profit from quarter horses because of              
          the time required to breed and train horses.                                
               In 1991, David Jordan (Jordan), a certified public                     
          accountant, told petitioners how to keep books and records that             
          they would need to make business decisions and that he would need           
          to prepare their income tax returns.  Jordan developed a                    
          recordkeeping system for petitioners based on their checking                
          account.  Petitioners kept detailed financial records as                    
          requested by their accountant.  They had a separate checking                
          account for their farm activity.  Petitioners called their farm             
          Blue Horse Farms.  Petitioners gave all of the records relating             
          to Blue Horse Farms to their accountant and relied on him to                
          prepare their returns properly.                                             






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