- 22 - We disagree. Petitioners’ financial statements for 1992, 1993, and 1995 show that petitioners believed their horses were valuable and were increasing significantly in value. Petitioner credibly testified that he expected petitioners’ horses and farm improvements to appreciate in value and that he expected to recover his losses by selling the appreciated assets. Thus, we give little weight to the fact that petitioners’ business plan contained no projections of appreciation in the value of petitioners’ business assets. Petitioners’ expectations were substantially corroborated by appraisals they obtained from O’Connor. Respondent did not challenge O’Connor’s appraisals for most of the horses except to point out that she used a 1998 valuation date. Respondent contends that O’Connor did not consider the effect Brigitta La Brisa’s inability to breed from 1990 to 1997 had on her value in 1996. We disagree. O’Connor did consider the fact that Brigitta La Brisa had difficulty breeding because she appraised her with foal ($30,000) and without foal ($20,000). Using the $20,000 amount in estimating the appreciation in value of petitioners’ horses, petitioners still had a substantial amount of appreciation from their horses. Respondent contends that petitioners should not have included Brilliant and Spanish Ballerina in their estimate of appreciation because they were born after 1996. We disagree.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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