Ralph E. Wesinger, Jr. and Catherine R. Wesinger - Page 6




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          types on the property and the potential plant communities for               
          such soils, but it did not indicate the number of cattle the land           
          was capable of supporting in its current condition.                         
               In 1996, petitioner placed cattle on his ranch for the first           
          time, grazing 23 head.  Animals were also placed on parcel 2 in             
          1997 and 1998, when 40 and 33 head, respectively, were grazed.              
          With regard to other activity on the property, petitioner dug an            
          additional well in 1996, began ripping the land in 1997 for                 
          purposes of growing alfalfa, and planted a 40-acre field of                 
          winter wheat in 1998.  He also obtained additional field                    
          inventory reports in 1997 and 1998.  The 1997 report recommended            
          grazing no more than 17 animals with the land in its current                
          condition, and all reports addressed the use of an irrigation               
          system to facilitate increased grass, crop, and animal                      
          production.  As of early 1999, no alfalfa had been planted, no              
          winter wheat had been harvested, and parcel 2 was not yet                   
          irrigated.                                                                  
               Through 1996, petitioner visited his ranch 15 to 17 times              
          per year and stayed 3 to 4 days per visit.  He kept no separate             
          books and records for his ranching operations, but he recorded              
          the checks and receipts relating to the ranch in a separate file            
          on his personal computer.  He then gave this information each               
          year to his accountant for use in preparing petitioners’ tax                
          return.                                                                     






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