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petitioners' horses until 1990. These drought conditions
also caused an increase in the cost of feed and depressed
the market for horses.
In 1994, General Motors transferred Ms. Hofer to its
plant in Dayton, Ohio. Because of this transfer, and
because Mr. Perry was planning to retire from General
Motors in 1995, petitioners decided to relocate their
home and horse breeding operation to a location nearer
Ms. Hofer's work. On or about June 3, 1994, petitioners
purchased 20 acres of real estate located in Montgomery
County, Ohio, for a total price of $141,273.14. This
included a house which petitioners used as their personal
residence from the time of the purchase up to the time of
trial, and a "home barn".
After acquiring the Montgomery County property,
petitioners began selling their real estate in Union
County. On or about July 26, 1994, petitioners sold the
1.72- and 4-acre parcels, together with the house and
barns, for a total price of $212,500. In December 1995,
petitioners sold 10 of the remaining 19.491 acres for a
total price of $35,000. At the time of trial, petitioners
were offering the remaining 9.491 acres for sale in three
parcels for a total price of $83,000. Petitioners were
also continuing to cultivate alfalfa on the remaining Union
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