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FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulation of facts and the attached exhibits are incorporated
herein by this reference.
At the time the petition was filed, petitioner resided in
Albuquerque, New Mexico.
Cattle-Ranching Business
Spirit Horse Ranch, Inc. (Spirit Horse Ranch), was
incorporated in New Mexico on July 3, 1986. The incorporation
documents listed Sonny Jim James as president and petitioner as
vice president, secretary, and treasurer. Spirit Horse Ranch
operated under several different names during the years in issue.
Spirit Horse Ranch was engaged in cattle-ranching activities
located near Grants, New Mexico. The activities included the
breeding of cattle, as well as the sale of steers (male calves) for
beef or roping. The cattle grazed on land owned by the El Morro
Valley Land Co. (El Morro). (Petitioner, who was a licensed New
Mexico real estate broker, sold El Morro's subdivisions and later
became the majority stockholder and president of that company.)
Spirit Horse Ranch acquired parcels from El Morro for its own
use. It maintained some improvements on the land, including
corrals, a boxcar (used for a shop), and a tack room to store
feed, saddles, and bridles. Petitioner also maintained three
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