Gustafson's Dairy, Inc. - Page 8

                                         -8-                                          

                     1988            5,849               2,473                        
                     1989            5,725               2,419                        
                     1990            5,262               2,634                        
                     1991            5,432               2,574                        
                     1992            5,285               2,226                        
                     1993            4,691               2,195                        

               Petitioner reduced the size of its dairy herd from 1983 to             
          1985 so it could participate in the Milk Diversion Program, which           
          was administered by the U.S. Department of Agriculture.  Dairy              
          and Tobacco Adjustment Act of 1983, Pub. L. 98-180, sec. 102(a)             
          (sec. 201(d)(3)(A) of the Agricultural Act of 1949), 97 Stat.               
          1128, 1129-1130.  The purpose of the program was to reduce the              
          production of raw milk in the United States.  Id.  Petitioner               
          received $2,052,061.30 ($398,343.50 in fiscal year 1984 and                 
          $1,653,717.80 in fiscal year 1985) from the program.  The program           
          ended on March 31, 1985.                                                    
               2.   The Dairy Association                                             
               During the years in issue, petitioner's dairy produced about           
          one-third of the raw milk it needed in its processing plant.                
          During the years in issue, petitioner sold all of the milk it               
          produced to a dairy cooperative, the Florida Dairy Farmers                  
          Association (Dairy Association), and bought all of the milk it              









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