Geraldine H. Pearson - Page 4

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          dissertation.  Petitioner has never employed anyone to help her             
          with the farm.                                                              
               Petitioner has managed horse shows and trials, worked on               
          farms in Oregon and Montana, acted as an agent in the sale of               
          cattle, sheep, and horses, managed a 2,000-head experimental goat           
          herd for the Oregon Health Sciences Center, and raised and sold             
          horses to the American Olympic Team.                                        
               Petitioner decreased her cattle and sheep holdings in 1985             
          because market conditions were poor.  She expanded her operations           
          in 1988 to include horticultural products.  There are two houses            
          on petitioner's farm.  Petitioner lived in one and rented the               
          other to Carl Schaeffer (Schaeffer) in 1988.  Schaeffer was not a           
          farmer.  Schaeffer lived at the house for less than 1 year.                 
               During the years in issue, petitioner had about 150 sheep,             
          20 to 25 head of cattle, and 40 tons of hay on her farm.                    
          Petitioner kept 8 to 10 horses on the farm for breeding.                    
          Petitioner worked full time on her farm during academic breaks              
          and summers.  During the school year, petitioner did farm work              
          mornings and evenings during the week and all day on weekends.              
          Petitioner cut, raked and bailed hay, hauled manure, reseeded               
          pastures, trimmed, weeded, sprayed, irrigated, maintained the               
          barn, repaired buildings and fences, bought and sold hay and                
          grain, and cultivated.  Petitioner also fed, castrated, docked,             
          inoculated, trained, marketed, shipped, and sold her livestock.             

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