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storing hay and was completed in early 1987 at a total
cost of approximately $13,000.
On or about June 15, 1987, petitioners purchased
4 additional acres of real estate contiguous to the 1.72-
acre parcel for a total price of $10,000. The party from
whom petitioners purchased this land retained the right to
harvest a crop already growing on the property. In 1988,
after this crop was harvested, petitioners tilled the soil
and converted the land to pasture. Petitioners also
constructed a second, larger barn on the 4-acre parcel.
This barn consisted of six bay stalls, one wash stall, a
tack room, and an "open run-in". The barn was completed
in 1989 at a total cost of $30,700.
On or about April 15, 1989, petitioners purchased
an additional 19.491 acres of land contiguous to the
4-acre parcel and adjacent to the 1.72-acre parcel for
a total price of $48,727.50. Shortly thereafter,
petitioners prepared a portion of the land for pasture
and the remainder for cultivating alfalfa. Petitioners
did not erect any structures on the 19.491-acre parcel.
Between 1986 and 1990, petitioners converted a total
of approximately 24 acres of the Union County real estate
from tillage to pasture and hay fields. Due to severe
drought conditions in 1987 and 1988, the pastures and hay
fields were not productive as sources of feed for
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