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equipment and supplies. The value of the acreage making up the
South Ranch as of May 11, 1992, was $1,270,500. The value of the
house and improvements on the South Ranch as of May 11, 1992, was
$70,000. The value of the acreage making up the South Ranch in
1993 and 1994 was $1,442,000. The value of the house and
improvements on the South Ranch in 1993 and 1994 was $90,000.
During the years in issue, petitioners spent a considerable
amount of time on the South Ranch. They fished and hunted on the
property. In addition, since 1987, they escorted family members
across the South Ranch on guided hunts.
Petitioners’ Cattle-Raising Operations
Petitioner had a lifelong interest in cattle ranching. He was
raised on his parents’ cattle ranch, where he gained practical
knowledge in raising and breeding cattle. Petitioner began his own
cattle-ranching activities when he purchased nine cows and one bull
in 1973; by 1994, petitioners owned over 300 head of cattle.
Petitioners bred and raised cattle. Cattle deemed surplus
were sold at biannual cattle auctions. The following numbers and
types of cattle were sold at auction:
Year Calves Cows Bulls
1992 75 0 4
1993 280 68 7
1994 28 6 1
1995 119 35 3
1996 255 133 0
1997 98 6 0
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