Mary Ann Tobin - Page 4




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          B.   Petitioner's Farm                                                      
               Petitioner owned about 3,300 acres of mostly contiguous                
          Kentucky farmland (including about 1,900 acres of cropland) in              
          1990 and 1991.  Petitioner raises cattle and horses and grows               
          corn, wheat, hay, and tobacco at her farm.  Petitioner developed            
          part of her farm into a public display garden called Broadmoor              
          Gardens, discussed below at paragraph I-D.  Petitioner grew no              
          corn or tobacco on her farm during the years in issue because she           
          leased the acres available for growing tobacco and participated             
          in the corn set-aside program.                                              
          C.   Petitioner's Residence                                                 
               Petitioner's residence was built in 1968 and 1969.                     
               1.   The Addition                                                      
               Petitioner added an addition to her residence in 1988 and              
          1989, at a cost of $623,027.  She added a conservatory (about               
          2,470 square feet or about 32' x 74'), a bedroom and office                 
          (hereafter called "petitioner's room") (875 square feet), an                
          office closet (about 104 square feet), a second bedroom                     
          (hereafter called "Ms. Beard's room") (about 468 square feet), a            
          bathroom containing a hot tub (about 625 square feet), a closet             
          that adjoins both petitioner's and Ms. Beard's rooms (about 256             
          square feet), and an attached structure called a "pole barn"                
          (about 1,680 square feet).  The addition is connected to the side           
          of petitioner's house.                                                      






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