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Petitioner’s home was on the land she bought in 1972.
Petitioner had horses on her farm while she raised her children.
She and her children enjoyed riding and caring for the horses.
Petitioner divorced in 1982 and became financially unable to show
or breed horses.
Petitioners married on July 21, 1988. At that time the land
contained one old barn. There were also about 10 acres of
cropland. Petitioner sold her home and about 1 acre of land in
1988. Petitioners built their present home on about 10 acres on
the farm before 1990. Petitioners bought about 21 acres
adjoining their property on March 20, 1995, for $2,000 per acre.
Petitioners cleared about 5 of the 21 acres to use as pasture.
In 1996, 50 of petitioners’ 88 acres were woodland, 21 acres were
cropland, 5 acres were pasture, and 10 acres were farmstead.
C. Petitioners’ Horse Breeding and Boarding Activity
1. Petitioners’ Use of the Land and Business Plan
Petitioners decided not to raise cattle because they neither
liked nor had any experience with cattle. Since around 1992,
they have sharecropped the 21 acres of tillable land with a local
farmer who grows tobacco.
Petitioners began in 1993 to breed, show, and sell quarter
horses. Petitioner was very familiar with them; people were
moving into their area and the number of horses was growing
rapidly; and they had some facilities and enough acreage to
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