Estate of Edward Brockenbrough, Deceased, Sharon Brockenbrough, and Suntrust Bank, Coexecutors, and Sharon Brockenbrough - Page 31

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               9.   Elements of Personal Pleasure                                     
               Petitioners did not conduct their horse and rodeo activity             
          for their personal pleasure.  Mr. Brockenbrough wanted to live on           
          a farm after he retired from Delta, but this fact does not show             
          that petitioners lacked a profit objective.  This factor favors             
          petitioners.                                                                
               10. Respondent's Other Contention                                      
               Respondent contends that Mr. Brockenbrough's letter to the             
          Meriwether Cattlemen's Association dated February 23, 1992, in              
          which he said that he hoped that he would "at least break even              
          for once" shows that petitioners did not have a profit motive.              
          We disagree.  We believe respondent is misconstruing Mr.                    
          Brockenbrough's statement in that letter, and that the letter               
          shows that petitioners wanted to make money.                                
               11. Conclusion                                                         
               Petitioners conducted their horse and rodeo activity in a              
          businesslike manner, consulted experts, kept adequate records,              
          developed expertise in the business, did not own the horses for             
          personal pleasure, and adjusted their plan in their attempt to              
          make a profit.  Mr. Brockenbrough spent many hours performing               
          physical labor and menial chores.  Petitioners abandoned their              
          horse and rodeo activity because of the death of some of their              
          horses, difficulties with Bumgarner, and other causes beyond                








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