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year of trial. Mr. Hightower generally keeps 20 to 22 horses.
In addition to breeding and selling horses, both Mr. Wilson and
Mr. Hightower earn income from training other people's horses.
During 1992, two of petitioners' horses were trained at Mr.
Hightower's ranch, and Mr. Hightower was paid $19,432 for
training and showing petitioners' horses for cutting horse
competitions. Mr. Hightower and Mr. Wilson provided advice with
respect to petitioners' breeding decisions, training of horses,
and competition. Their advice did not cover the financial
aspects of running a cutting horse operation.
Mr. Sullivan was employed as an investment manager with
Sullivan Money Management, Inc., in 1992 and previously with
Painewebber, Inc. His earnings from employment were as follows:
Year Earnings
1989 $90,000.00
1990 90,000.00
1991 97,500.00
1992 108,750.00
1993 101,250.00
1994 90,000.00
1995 107,992.20
He has both a bachelor and master of business administration
degree from the University of Texas.
The value of a cutting horse depends upon its possession of
desirable physical characteristics (conformance), its
demonstrated proficiency in cutting horse competitions, and, in
the case of a stallion, its demonstrated capacity to pass along
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