Thomas E. and Susan L. Truskowsky - Page 8

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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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