Estate of Edward Brockenbrough, Deceased, Sharon Brockenbrough, and Suntrust Bank, Coexecutors, and Sharon Brockenbrough - Page 28

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               Jordan and Mr. Brockenbrough testified that Mr.                        
          Brockenbrough consulted with Jordan about horse breeding and                
          training, rodeos, and fairs.  Respondent contends that Jordan had           
          no experience with the horse business or fairs.  We disagree.               
          Jordan had raised horses, and had prepared several tax returns              
          for people who participate in the Cotton Picking Fair.  Jordan              
          also had been associated with the Cotton Picking Fair for 25                
          years.                                                                      
               Respondent points out that there is no evidence that                   
          Bumgarner had operated a horse operation for profit.  However,              
          Bumgarner had a good reputation as a trainer and rodeo operator.            
          There is no indication that petitioners should have known that              
          Bumgarner would misuse their property.  Respondent also contends            
          that Bumgarner's low salary shows that he was not qualified.  We            
          disagree.  Cashion testified that a manager such as Bumgarner               
          would typically be paid a salary such as petitioners paid plus a            
          percentage of income earned in the activity.                                
               This factor favors petitioners.                                        
               3.   Taxpayer's Time and Effort                                        
               Mr. Brockenbrough spent a lot of time and effort in the                
          horse and rodeo activity.  He did bookkeeping, horse                        
          registration, and manual labor such as putting up hay and                   









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