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to the ponds, which they are depreciating over a period of
19 years. Petitioners reported income of $525 from the
sale of fish in 1990, but they did not report any income
from the fish-raising activity in any of the other years in
issue. Although there were no fish in either of the ponds
at the time of trial, petitioner planned to restock the
ponds once the windmills and plungers were operational.
Christmas Trees
Sometime prior to 1987, after consulting representa-
tives of the local Soil Conservation Service (SCS) office,
petitioner decided to plant Christmas trees on his
property. Petitioner had gained some experience harvesting
and selling Christmas trees while working on his father's
property as a young man.
Sometime after 1987, petitioner borrowed a tree-
planting device from the SCS and planted 500 to 1,000
trees on his property. Petitioner planted more trees in
subsequent years in an attempt to establish a continuous
rotating crop. Petitioner planted these trees in rows
approximately 5 feet apart. Some of the trees are planted
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