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and F & W Forestry Services, Inc., were retained by Treeco to
provide consulting and management services for the tree farms.
Contained in the record are a Five-Year Timber Operating Budget
for the McIntosh County Farm, prepared by F & W Forestry
Services, and detailed forest management plans for the Putnam and
Flager County Farms, prepared by Georgia Pacific. These
documents discuss, among other things, plantation thinning,
reforestation, fertilization, and capital improvements. The F &
W Forestry Services budget projects losses through 2000 but
characterizes the McIntosh tract as having “great future income
potential”. The Georgia Pacific plan describing the Putnam
property similarly states: “These recommendations, if followed,
will provide you with a healthy, fast growing forest which will
lead to a steady stream of income in the future.” A.J. Hackl
meets on a regular basis with consultants from Georgia Pacific
and F & W Forestry Services regarding maintenance of the tree
farms. The parties have stipulated that he has always managed
Treeco and its successors with such care as an ordinarily prudent
person in a like position would use under similar circumstances.
The primary business purpose of all three of the above
entities has been to acquire and manage plantation pine forests
for long-term income and appreciation for petitioners and their
heirs and not to produce immediate income. Petitioners
anticipated that all three entities would operate at a loss for a
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