Harland and Shirley Stonecipher - Page 4




                                         -4-                                          
               From 1981 through 1997, petitioners purchased additional               
          unimproved property adjacent to or near the 40 acres, as follows:           

                                                  Petitioners’ Cumulative             
            Year    Acres Purchased    Cost      Total Acreage At Yearend             
            1981          50          $10,000              190                        
            1982          160         38,750               250                        
            1985          220         66,000               470                        
            1986          220         55,000               690                        
            1992          300         75,000               990                        
            1993          220         6,000                1,210                      
            1995          60          18,000               1,270                      
            1995          5           6,000                1,275                      
            1996          320         96,000               1,595                      
            1996          200         40,000               1,795                      
            1997          40          10,000               1,835                      
               1 The 90 acres comprises the original 40 acres purchased in            
          1975 plus the 50 acres purchased in 1981.                                   
               Petitioners generally paid from $200 to $350 an acre for the           
          property described above, much of which was wooded or partly                
          wooded.                                                                     
               Also, during 1993, 1994, and 1995, petitioners leased 2,680            
          additional acres located near the above property.                           
               By 1999, petitioners owned approximately 2,000 acres and               
          leased an additional 2,680 acres.  Petitioners’ fee ownership and           
          leasehold interest in the above property apparently did not                 
          include the right to mineral interests in the property.                     
               Since 1982, when petitioners first purchased cattle to raise           
          on their property, petitioners have made improvements to the                
          property, in addition to those improvements previously mentioned,           





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