Robert E. and Carloyn S. Holmes - Page 6

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             petitioners claimed a basis of $50,000 in the 120-acre                   
             parcel.                                                                  
                  Petitioners engaged in a variety of activities on the               
             5-, 40-, and 120-acre parcels during the years in issue,                 
             including growing Christmas trees, raising fish, preparing               
             timber for harvest, and planting row crops.  Petitioners                 
             also placed a portion of the property in various Government              
             subsidy programs, received disaster relief payments in                   
             connection with a portion of the land, and made depreciable              
             improvements to the land.  Petitioners treated these                     
             activities as "farm activities" and reported the following               
             income and expenses from these activities for the years in               
             issue:                                                                   























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