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of the Chireno ranch. Mr. Smith did not maintain written records
with regard to the number of hours he cared for the Chireno
ranch. Petitioners compensated Mr. Smith for his services by
providing him with part of the bailed hay. In addition to his
work at the Chireno ranch, Mr. Smith worked for a local cable
company installing cable and operated a ranch in Nacogdoches.
Colorado Ranch
In 1983, petitioners purchased 1,200 acres of land, 10 miles
east of Guffey, Colorado (Colorado ranch), for $550,000. The
Colorado ranch includes a house and a barn.
On the Colorado ranch, the growing season lasts only 30 to
60 days during a normal year. The grazing season lasts only 90
days. Because of this short grazing season, the Colorado ranch
can only serve as a summer steer or heifer operation.
In 1984, severe rains caused a major flood on the Colorado
ranch. As a result of the flood, the hay meadows and the grasses
on the Colorado ranch were severely damaged. To maintain revenue
from the sale of hay and to provide any steers and heifers on the
Colorado ranch with fields on which to graze, petitioners had to
reestablish the hay meadows and the grasses.
From 1984 to 1993, petitioners participated in a Government-
sponsored conservation program to replant the hay meadows and the
grasses. Under the terms of the conservation program,
petitioners could not graze cattle on several sections of the
Colorado ranch during the replanting period. The replanting
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