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petitioners employed David Randall as full-time manager of the
ranch.
In 1983, corrals were built on the ranch to hold the cattle,
and petitioner and Lichen built a barn on the ranch. Also in
1983, petitioner read several brochures, talked with several
breeders of Brangus cattle, and concluded that Brangus cattle
constituted a superior breed of cattle. Petitioner then decided
to raise and sell Brangus cattle on the ranch. Petitioner paid
$148,500 for the implantation of 33 Brangus cattle embryos in the
cows on the ranch.
From 1984 on, petitioner visited the ranch infrequently. On
weekends, petitioners and their children would occasionally use
the ranch as a weekend retreat, and petitioner occasionally
hunted on the ranch. In order to learn more about cattle, each
week petitioner spent a few hours reading cattle journals,
magazines, and catalogs.
Petitioner attempted to increase the number and quality of
Brangus cattle on the ranch by having the cows bred using
artificial insemination. Petitioner also bought five Brangus
cows with calves. Petitioner generally would sell the bull
calves and retain the heifers or female calves for future
breeding purposes.
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