James Tinnell - Page 6

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               During 1980, petitioner located and staked at least 47 lode            
          mining claims in Clark County, Nevada.8  During the 1980's,                 
          petitioner conducted exploration and development activities with            
          respect to his claims.  As of February 2000, petitioner had on              
          file and of record more than 300 lode mining claims.  A “Resource           
          Management Plan” map, dated August 1, 1997, prepared by and for             
          the U.S. Department of the Interior, Bureau of Land Management              
          (BLM), indicated there is “high mineral potential” on and around            
          petitioner’s mining claims.                                                 
          B.  Petitioner’s Early Efforts To Generate Income From                      
               Petitioner engaged in business discussions regarding his               
          mining activities with various parties and entities.  In December           
          1982, petitioner discussed the possible sale of ore to Cash                 
          Industries of Idaho (Cash Industries) for processing at Cash                
          Industries’ facilities.  During December 1982 and January 1983,             
          petitioner and Cash Industries conducted a sampling program and             
          numerous assays on petitioner’s claims.  No sale resulted.                  
               In April 1983, petitioner engaged in discussions with Lud              
          Carrao, the owner of a construction company, regarding a joint              
          venture in mining.  The venture was subject to proof of the                 
          economic and commercial value of petitioner’s claims.  Petitioner           

               8Most of petitioner’s claims were located in the Newberry              
          Mountains southeast of Searchlight, Nevada, which is an area                
          recognized for its high mineral potential.                                  

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