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(3) whether petitioner is entitled to costs of goods sold
in the amounts of $4,890, $16,850, and $1,400 for the years 1991,
1992, and 1993, respectively; and
(4) whether petitioner is liable for accuracy-related
penalties under section 6662(a) for negligence or disregard of
rules or regulations.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, together with the exhibits attached
thereto, is incorporated herein by this reference. Petitioner
resided in Rhodes, Michigan, at the time the petition was filed.
Petitioner owned two improved properties (hereinafter
referred to as the Rhodes property and the Whitefeather property)
that she used in her farming and breeding businesses. The
properties were located across the street from each other.
Petitioner farmed hay and straw, sold goats and pigs (1991 only),
and raised poodles and quarter horses for sale.
The Rhodes Property
Petitioner had leased the Rhodes property since 1978 or
1979. Petitioner purchased the Rhodes property in 1985 from a
longtime family friend whom she had taken care of during the last
years of his life. She paid $25,000 and other noncash
consideration for the property. The total purchase price is
unknown. When purchased, the property consisted of 20 acres, a
house, a granary, a large barn (Rhodes barn), two chicken coops,
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