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did not construct on the ranch any fancy or showy fences or make
other improvements that would be indicative of a dude ranch.
The cattle petitioners purchased and raised on the property
were Brahman crossbreed cattle suited to that part of Oklahoma
because of their ability to tolerate rough grazing conditions,
because of their thin hides that enabled them to tolerate the
Oklahoma heat better than other cattle, and because of their high
tolerance for insects and parasites. Also, Brahman crossbreed
cattle have smaller calves, making calving easier. Petitioners’
cattle were not shown at cattle shows.
Generally, petitioner worked only a limited number of hours
on the ranch each week-–an hour or two on weekday evenings and a
number of hours on Sundays. Occasionally, petitioner himself
would participate in bulldozing the land and in worming,
dehorning, castrating, branding, and vaccinating the cattle.
Since 1987, petitioner has employed on the ranch either one
of his sons or another full-time hired hand. On weekday
evenings, petitioner occasionally would talk to his employed son
or to the hired hand about management of the ranch.
Occasionally, petitioner pulled calves out of the cows at calving
and brush-hogged (cleared brush from) the land.
The ranch land was fertilized and sprayed for weeds.
Rotational grazing of the cattle generally was not done in this
part of Oklahoma, and it was not done on petitioners’ ranch.
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