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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
Mining
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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