Hugh G. and Norma J. King - Page 3

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                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               Hugh G. King (Mr. King) and his wife, Norma J. King (Mrs.              
          King), resided in Dothan, Alabama, when the petition was filed.             
          A.   Petitioners’ Early Years                                               
               Petitioners grew up on farms and are high school graduates.            
          Mr. King managed his family’s farm from 1939 to 1942 and served             
          in the Air Force from 1942 to 1946.                                         
          B.   Petitioners’ Income-Producing Activities                               
               Mr. King entered the construction and sand and gravel                  
          businesses around 1965.  Petitioners bought an appliance store              
          around 1966, discussed below in paragraph C.  In 1978, Mr. King             
          inherited a 250-acre farm, 47 acres of which were cultivated.               
          The rest was forested.  A sharecropper farmed the cultivated                
          land.                                                                       
               Mr. King bought more land after 1978.  Petitioners owned 537           
          acres of land in 1995, including 230 acres of cropland.                     
          Petitioners owned 682 acres of land in 1996-98, of which 342                
          acres was cropland.  They sold sand mined from their land and               
          grew timber during the years in issue.                                      
               During 1995-98, Mr. King received a peanut quota from the              
          U.S. Department of Agriculture based on production in past years            
          from his farm.  The peanut quota allowed him to sell a specified            
          amount of peanuts (quota peanuts) for about $600 per ton during             






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