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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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