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plan, however, in the long term Flying H would be able to run
more cows and, therefore, make more money. To assist this
process, Dr. Haaland recommended that petitioner directly manage
the ranch rather than allow the rate-of-gain contracts to
continue. He concluded that through direct management petitioner
could correct the condition of the land and make it more
productive.
Thereafter, petitioner attempted to develop Flying H as a
typical western cattle ranch. In 1988, Flying H initiated a
yearling grazing stocker program.8 Consistent with its plan to
reestablish its pasture, the ranch ran only 305 and 393 head of
cattle in 1988 and 1989, respectively. As the pastures improved,
the ranch increased the number of cattle it grazed to 780 head in
1990, 1,256 in 1991, 1,447 in 1992, and 1,971 in 1993. The
location of Flying H is an excellent habitat for elk, deer,
antelope, and other species of American wild game. Petitioner
recognized that the ranch presented a lucrative opportunity to
offer big game hunting, because demand for hunting was increasing
and hunters were willing to pay substantial fees to hunt big
game. For instance, other ranches in the same general area
charged as much as $9,000 for an elk hunt.
8 In a "stocker" program, yearling cattle are purchased each
spring from a cow-calf operation, fattened over the summer, and
then resold in the fall. In a cow-calf operation, the ranch owns
the cows that it breeds.
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