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the 640 acres of ranch land, bringing the total ranch acreage to
2,560 acres.
The 2,560 acres of land consisted of 900 acres suitable for
grazing of cattle, 1,000 acres of canyon land not particularly
suitable for grazing of cattle, 110 acres covered by mesquite
trees, and 550 acres that, because of their inclusion in a
Government conservation program, could not be used for grazing of
cattle. The 900 acres suitable for grazing of cattle represented
35 percent of the total ranch acreage.
From 1974 through 1982, petitioner alone worked on the
ranch. Mrs. Goforth did not participate in raising the cattle,
nor in other work on the ranch. During those years, petitioner
spent considerable time on the ranch, visiting the ranch almost
each day after completing his work as a doctor. In 1982,
petitioner began cross-breeding Angus-Hereford cattle with
Brangus bulls and selling the cross-breeds. Petitioner believed
he could realize more income from sale of the cross-breeds than
from sale of Angus-Hereford cattle.
In 1983, petitioner had a house built on the ranch that was
intended for use as an eventual retirement home for petitioners.
The home had a view overlooking the scenic Dripping Springs
Canyon.
From 1983 through 1988, petitioners employed Greg Lichen as
full-time manager of the ranch, and from 1988 through 1994,
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