- 28 - 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 andPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
Last modified: May 25, 2011