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the cattle close enough to observe their general condition.
Petitioners would sometimes stop on the way to the farm to
purchase the grain, which took from a 1/2 hour to 1 hour. The
farm, located between Gettysburg and Mechanicsburg, Pennsylvania,
was halfway between petitioners' home in Trappe and Mrs.
Truskowsky's mother's home near Washington, D.C. The distance
between Trappe and the farm is approximately 99 miles. Like Mrs.
Truskowsky's mother's home, the Oracle office where Mrs.
Truskowsky worked is located in the Washington, D.C. area. It
was convenient for Mrs. Truskowsky, when she visited K-C on the
weekend, then to go to stay at her mother's house to prepare for
the coming work week instead of returning home to Trappe.
Petitioners' Farm Search
Petitioners had a desire to acquire a farm of their own.
During 1996 and 1997, they used the services of a real estate
agent to aid them in locating one. Petitioners made trips with
an agent to look at farm property offered for sale. Petitioners
eventually purchased a farm in West Virginia in November of 1998.
Reconstructed Logs and Tax Returns
Although petitioners maintained certain records of their
Limousin cattle activity, they did not keep any log of the actual
number of hours they devoted to the activity. At the request of
their attorneys, petitioners prepared for use at trial documents
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