Gary G. and Linda J. Hart - Page 5

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               The Tobacco Barn was not completed until November 1994, and             
          petitioners did not cure tobacco in the Tobacco Barn during 1994.            
          After its completion, petitioners used the Tobacco Barn for                  
          stripping, grading, and baling the tobacco leaves.                           
               Since 1994, petitioners have used the Tobacco Barn in a                 
          substantial part of their tobacco business, including the curing,            
          stripping, grading, baling, and boxing of the tobacco leaves.                
          During curing season, petitioners use the Tobacco Barn mainly as             
          a curing facility.  During that season, all of the work performed            
          in the Tobacco Barn is related to the curing of the tobacco.  For            
          example, the Tobacco Barn is not equipped with a cable hoist                 
          system, and tobacco is hung manually by petitioners and their                
               After the curing season, petitioners use the Tobacco Barn               
          for about 5 months of the year for stripping, grading, and                   
          baling, and boxing of the tobacco leaves in what is commonly                 
          referred to as a stripping room.  A good stripping room is                   
          essential to tobacco producers for preparation of the tobacco for            
          market.  A stripping room need not be located inside a tobacco               
          barn.  In fact, it is preferable to haul the unstripped tobacco              
          to a more suitable location.  However, smaller producers suffice             
          by temporarily enclosing a portion of their barn with plastic and            
          using a foldup bench and portable heat.  Petitioners chose this              
          latter option.                                                               

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