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Wildlife Department on how to manage and feed herds of deer.
Additionally, petitioner had aerial surveys made of roaming deer
herds in order to observe the herds’ development. Petitioners’
son, Byron, was employed full time to manage their deer operations;
his salary was paid by United.5
Petitioner initially planned to conduct guided trophy hunting
expeditions on the South Ranch. Petitioner estimated that when
fully operational, these hunts would generate a net income stream
of $38,600 per year. During the years in issue, petitioner had not
begun conducting these guided hunting expeditions on the South
Ranch because of the lack of trophy bucks on the property.
According to petitioner, it takes on average 4-1/2 years from the
beginning of a breeding program for a fawn to develop into a mature
trophy buck.
Petitioners’ General Financing and Accounting Practices
Petitioners’ cattle-raising and deer operations are
leveraged. At the time of trial, petitioners owed between $130,000
and $150,000 of debt incurred in operating both ranches.
During the years in issue, petitioners did not maintain
5 During the years in issue, Byron Kahla was paid the
following amounts by United:
1992 $33,837
1993 226,969
1994 205,825
Petitioners did not claim Byron Kahla’s salary as a Schedule F
expense.
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Last modified: May 25, 2011