Courtney and Brenda Lundquist - Page 21




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          years in issue.2  Petitioner's limited advertisements do little             
          to show that she conducted her activity in a businesslike manner.           
                    g.     Emerson                                                    
               Emerson testified that petitioner operated her activity in a           
          businesslike manner.  We disagree.  Emerson first met petitioner            
          in 1993 or 1994.  He did not know how much she earned from stud             
          and boarding fees or the sale of foals.  He never saw business              
          records or a business plan for petitioner.                                  
               Emerson was a member of the U.S. Equestrian Team that                  
          competed in the 1974 world championships and the 1976 Olympics.             
          He was national 3-day champion in 1976 and 1979.  Emerson                   
          attributes his financial success to his personal fame.                      
          Petitioner lacked this advantage.                                           
               Emerson received gross receipts of about $50,000 from                  
          breeding 3 stallions and 75 to 80 mares.  The rest of his income            
          was from clinics and training.  Petitioner had one lame stallion            
          and a few mares.  She had no income from training or clinics.               
               Emerson's conclusion that breeding Temptation could have               
          been profitable is not enough to show that petitioner had an                
          actual and honest profit objective.                                         
               This factor favors respondent.                                         






               2 Petitioners deducted advertising expenses of $878 for                
          1988, $628 for 1989, and $632 for 1990.  The record includes no             
          information about these expenses.  In 1991, petitioner advertised           
          that Labrette was for sale.                                                 

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