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Petitioners spent a considerable amount of time on the North
Ranch each year. Besides using the North Ranch for their cattle
ranching, petitioners regularly entertained family members on
holiday occasions, and petitioner frequently hunted on the
property.
The South Ranch
The South Ranch is located approximately 320 miles from
petitioners’ home. During the years in issue, it comprised
approximately 3,578 acres.3 The land was acquired as follows:
Date Acres Acquisition Price
9/88 1,073.47 $354,245.10
11/88 648.14 213,886.20
2/89 (31.57) 1(10,418.00)
4/89 1,169.54 409,339.00
10/89 500.00 200,000.00
12/92 218.00 65,400.00
Total 3,577.58 11,232,452.30
1 Petitioners sold 31.57 acres in February 1989.
The South Ranch is essentially a large pasture suitable for
cattle grazing and is located in an area that is subject to
drought. In addition to its large open grazing areas, the South
Ranch contains several buildings and fixtures, including a large
residence and two “outbuildings”. The residence is often used by
petitioners both as a personal retreat and as lodging for visiting
guests. The outbuildings are primarily used to house farm
3 An additional 438.66 acres was acquired on Feb. 13,
1997, for $153,673.
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