Mr. and Mrs. Smith, ages 67 and 68, are planning to retire within the next 5 years. As part of their estate planning, they had recently sold off several investment real estate holdings. The largest remaining real estate investment was a ranch located near Comfort, Texas, about an hour north of San Antonio. They had purchased the ranch many years earlier for recreational, hunting, and investment value. In recent years, they had begun to lease the ranch to hunters, but the income generated was insufficient and inconsistent. Located in a highly desired Hill County area, the value of the ranch had grown from their original cost of $ 650,000 to a current market value of at least $ 3,000,000.