Harold W. and Julia A. Kahla - Page 7




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               Initially, petitioner did most of the chores around the North          
          Ranch.  As their operations grew, petitioners hired contract labor.         
          In addition, during the years in issue, two employees of United             
          (Jerry Scott and Perfecto Delgado) worked as caretakers on both             
          ranches.  Although paid by United, petitioners claimed Messrs.              
          Scott’s and Delgado’s salaries as Schedule F expenses.                      
               From the inception of their cattle-raising operations,                 
          petitioners’ Schedule F expenses exceeded income; this result is            
          expected to continue for the foreseeable future.  (Petitioners              
          incur a net loss of approximately $11.85 for every head of cattle           
          sold.)  Petitioners attribute these continued losses to fluctuating         
          cattle and feed prices due in large part to increased competition           
          in the industry as well as a prolonged drought.4                            
          Deer Operations                                                             
               In 1988, petitioner decided to raise and manage deer so that           
          he could eventually develop a herd suitable for trophy game                 
          hunting.  For this purpose, petitioners acquired the South Ranch            
          and enclosed the property with deer-proof fencing.  In addition,            
          petitioners installed a water and feed system across the South              
          Ranch in order to ensure a constant supply of food for the deer.            
               Although petitioner had an extensive knowledge of deer from            
          previous hunting trips, he sought advice from the Texas Parks and           

               4    We note that during 1992 through 1994, prolonged                  
          drought conditions did not exist in the areas surrounding the               
          North and South Ranches.                                                    





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