-5-
related to raising cattle, at a cost to petitioners, where
indicated in the record, as follows:
Improvement Cost
Barn $40,000
Cabin 40,000
2-1/4 mile fence 30,000
3 ponds --
Horse/cattle shed --
During 1993, 1994, and 1995, petitioners’ property was also
the site of a tenant house and a mobile home, occupied for a
period by petitioners’ son.
Petitioners may be regarded as first-generation cattle
ranchers in the sense that they did not receive or inherit any
cattle from their parents. Instead, petitioners had to purchase
their initial head of cattle. From 1982 through 1992 or 1993,
petitioners sold the cattle that they raised each year, including
all the male and female calves. After market prices fell in
1992, petitioner began retaining most of the female calves, until
1998, when he began selling them again.
Petitioners’ cattle ranch may accurately be described as a
no-frills cattle operation. Petitioners’ improvements to the
ranch property were not extravagant. Neither petitioners nor
other members of petitioners’ family, some of whom also lived on
the property, made significant recreational use of the ranch
property. There was no swimming pool, golf course, tennis court,
Jacuzzi, or other significant recreational amenity. Petitioners
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