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profitable. Petitioners eventually sold the fiberglass business
for several million dollars in the early 1980s.
Petitioners considered themselves retired after they sold
their fiberglass business, when Mr. Bangs was approximately 40
years old. Petitioners owned several rental properties during
the years at issue that generated between $400,000 and $500,000
annually in gross income.
The Farming Activity
Petitioners purchased 40 acres of land in California’s
Valley Center area in 1971. They had been looking for property
for some time and were able to obtain this property at a good
price. When petitioners sold their fiberglass business in the
early 1980s, they decided to build a 6,000 square foot house on
the Valley Center property. Mr. Bangs hoped to get back to
farming and was looking for something he could do in his backyard
when he was 70 and retired. Petitioners had fond memories of
farming from their youth and were interested in learning whether
it was possible to replicate their experiences in California.
Petitioners spoke to an agricultural adviser and asked what
type of crop could be grown on the land. This expert advised
petitioners to grow lemons because they were fairly hardy and
could thrive with little water. Mr. Bangs also learned that
lemon trees had a long life.
Petitioners planted some lemon trees on their property in
the early 1990s. The record is unclear, however, how many trees
were planted. Petitioners also made some improvements to their
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