William T. Shipes, Jr. and Kathy D. Shipes - Page 2

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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)               


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