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B. Dairy Operations
1. Milk Production and Processing
Petitioner operates a dairy farm that produces raw milk.
During the years in issue, petitioner's dairy herd was one of the
largest in the United States at one location. Petitioner also
operates a dairy processing plant that produces finished dairy
products and a milk distribution business. Petitioner's dairy
farm and milk processing plant border the southern city limits of
Green Cove Springs. Petitioner's operations have gradually
shifted over the years, including the years at issue, from milk
producing to milk processing. Petitioner also owns and manages a
beef herd, grows timber, and raises crops.
Petitioner has an open herd rather than a closed herd. In
an open herd, replacement cows are bought from third parties. In
a closed herd, replacements are raised from calves on the farm.
Petitioner had in inventory and bought the following number of
cows from fiscal year 1983 to fiscal year 1993:
Dairy Dairy
Fiscal year cattle inventory cattle purchased
1983 7,585 not available
1984 6,770 not available
1985 5,920 1,458
1986 6,100 2,863
1987 6,004 2,707
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