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agriculture courses. However, he attended farm community
meetings, read farming magazines, and discussed farming issues
with farmer clients, friends, and other farmers.
C. Petitioners’ Residence
In August 1978, petitioners bought a house at 502 North
Hickory in Salem, Missouri. Petitioner lived in that house until
November 1991, and has lived in the house at the Mitchell farm
since then. Mrs. Mitchell and petitioners’ two sons lived at 502
North Hickory until August 1995 when they moved to the house on
the farm.
In November or December 1995, petitioners agreed to let
Toney E. Hill III (Hill), live at 502 North Hickory rent free. In
exchange, Hill agreed to make improvements to the house and pay
the utilities.
Hill did not pay all of the utilities. As a result, the
electric and water services were disconnected from June 12 to
August 15, 1996. Hill moved out in mid-1996.
Petitioners did not receive any rental income from 502 North
Hickory in 1995, 1996, or 1997, and they did not advertise 502
North Hickory for rent or sale during those years. They included
it in one of their homeowner’s insurance policies until August 6,
1997, when they sold 502 North Hickory.
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