Estate of Edward Brockenbrough, Deceased, Sharon Brockenbrough, and Suntrust Bank, Coexecutors, and Sharon Brockenbrough - Page 10

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                    c. Hiring Bumgarner                                               
               Petitioners hired Bumgarner to manage Blue Horse Farms.                
          Bumgarner fed the animals, helped keep the barn clean, trained              
          the foals, showed the horses, and supervised the arena and                  
          weekend roping events.  Petitioners paid Bumgarner about $400 per           
          week plus a percentage of their income from the horses.  Paying a           
          manager that amount of salary plus a percentage of income was               
          customary for a farm like petitioners'.                                     
                    d.   Operations                                                   
               Petitioners began to operate their horse activity in 1991.             
          Petitioners reported having six employees for the farm in 1991.             
          Petitioners' employees provided services including training,                
          boarding, shoeing horses, and giving riding lessons.  Petitioners           
          obtained insurance for their horse activity.  Petitioners                   
          expected that their animals would breed and increase in number.             
          Petitioners expected to train the foals to increase their value,            
          and then to sell them.                                                      
               John Brockenbrough, Mr. Brockenbrough's son, worked at Blue            
          Horse Farms after he graduated from college.  He overfed a mare             
          which caused her death.                                                     
               Mr. Brockenbrough was not a horse trainer, but he did a lot            
          of the dirty work relating to the horses, such as putting up hay            
          and cleaning the stalls.  He gave the animals shots and vitamin             
          supplements.  He did not ride horses in 1991 and 1992.  Mr.                 
          Brockenbrough told Bumgarner not to contact him while he was on             




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