Robert E. and Carloyn S. Holmes - Page 12

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             under overhead wires.  Some of the trees are visible from                
             petitioners' house.                                                      
                  In addition to the cost of the trees, petitioner                    
             incurred costs for herbicide and trimming services.  At                  
             trial, petitioner estimated that Christmas trees were                    
             growing on approximately 15 of his 165 acres, but he was                 
             unable to estimate the total number of trees growing on                  
             his property.  Petitioner did not harvest or sell any trees              
             during any of the years in issue but thought that he could               
             begin harvesting trees approximately 2 years after the time              
             of trial.                                                                

             Timber                                                                   
                  Sometime between 1986 and 1988, petitioner began                    
             considering the prospect of selling timber located on the                
             120-acre parcel.  Petitioner had obtained some experience                
             harvesting and selling timber after his father died, when                
             he sold trees that were growing on his father's land.                    
             Petitioner spent some time during the years in issue                     
             removing dead, crooked, and otherwise unwanted trees and                 
             brush from his property in an attempt to manage the                      
             timberland.  However, petitioner did not harvest or sell                 









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