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replacement periods in connection with a single condemnation of
property. If we decide that section 1033 permits the use of
multiple replacement periods, we must then decide whether
petitioners replaced converted property with qualified
replacement property.
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. At the time the petition was filed in this
case, petitioners resided in the State of Florida. Petitioners
are husband and wife and filed a joint Federal income tax return
for taxable year 1991.
Petitioner-husband (Mr. Shipes) is a nurseryman by
occupation. Sometime during the late 1970's and early 1980's, he
purchased 10 acres of real estate located in Orange County,
Florida, and began a business thereon in which he grew and sold
various types of plants and trees. In 1984, Mr. Shipes began a
citrus nursery (the Nursery) on the above-mentioned land. The
Nursery produced and sold citrus seedlings. The Nursery's
seedlings were never part of the above-mentioned real estate.
On October 25, 1985, as part of an eradication project (the
Eradication Project) with the U.S. Department of Agriculture
(USDA), the State of Florida Department of Agriculture (SFDA)
1(...continued)
Procedure.
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