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carve out, and Carrie thereby became sole owner of the 20-acre
carve out.
After the September 1998 sale of the farm acreage to Carrie,
Tracy, and Deborah, and through the time of trial herein in 2004,
the farm acreage has continued to be owned by Carrie, Tracy, and
Deborah. Hay is grown, and cattle and horses belonging to
Carrie, Tracy, and Deborah are grazed thereon.
After the May 2000 sale of the residence acreage to a third
party and through the time of trial herein, Richard has continued
to live either in a trailer home or in a workshop located on the
20-acre carve out owned by Carrie. The residence acreage that
was sold in 2000 is still owned by the individuals who purchased
it in 2000.
On June 23, 2000, in an effort to collect Richard’s unpaid
Federal income tax liabilities for 1995 and 1996, respondent,
among other things, issued payment-due notices to Richard, filed
tax liens against Richard, and mailed to Richard notices of
intent to levy.
In July 2002, a valuation expert for respondent valued the
farm acreage as of September 9, 1998, at a fair market value of
$176,000.
As of August 6, 2002, the $23,278 for 1995 and $20,238 for
1996 in Federal income taxes that Richard owed and that had been
assessed against Richard had not been paid, and respondent on
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