George Vajda - Page 3




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                                  FINDINGS OF FACT                                    
               Many facts were stipulated.  The parties’ stipulation of               
          facts and the exhibits submitted therewith are incorporated                 
          herein by this reference.  The stipulated facts are found                   
          accordingly.  When petitioner’s petition was filed, his mailing             
          address was in Hackensack, New Jersey.  TBP’s mailing address was           
          also in Hackensack, New Jersey, when a petition was filed on its            
          behalf.                                                                     
               In 1975, Alpha Farms, Inc. (Alpha), an entity whose                    
          principal shareholder is petitioner, purchased 93.97 acres of               
          unimproved land (land) in Upper Freehold, New Jersey, for                   
          $197,337.  The only structure on the land was a hay barn that was           
          built around 1900.  From 1978 to 1980, Alpha erected various                
          buildings (buildings) on the land to transform the land into a              
          horse breeding farm (collectively, the buildings and land are               
          referred to as the farm).  These buildings included:  (1) A two             
          bedroom, two bath house, (2) a grooms’ quarters and office                  
          consisting of eight rooms and a double and single bath, (3) a               
          concrete barn with 16 stalls, (4) a steel barn with 22 stalls and           
          an x-ray room, (5) a training arena with 10 stalls and an indoor            
          exercise area with an artificial surface, (6) an equipment shed,            


               2(...continued)                                                        
          hold for respondent.  The record contains no evidence that would            
          support a holding for petitioner as to those issues.  See Rule              
          142(a).                                                                     





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