Robert E. and Carloyn S. Holmes - Page 9

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             Fish Raising                                                             
                  Sometime prior to 1987, after reading articles in a                 
             local trade magazine and attending at least one seminar                  
             at the Michigan State Biological Station, petitioner began               
             to raise fish in two ponds located on his property.  It is               
             unclear from the record whether these ponds were on the                  
             property at the time of petitioners' acquisition or whether              
             petitioner constructed one or both of them himself.                      
                  Petitioner began his fish-raising activity by digging               
             small holes on the property to determine whether the ponds               
             would hold water.  Petitioner then tested the temperature                
             of the water in the ponds to determine whether fish could                
             survive in them.  After concluding that the water was                    
             suitable for raising fish, petitioner enlarged both ponds                
             and covered the bottoms with lining material.  Petitioner                
             then purchased approximately 100 trout for approximately                 
             $1.75 to $2.50 each, and an undisclosed number of catfish                
             for approximately 10 cents each, to stock the ponds.                     
             Petitioner placed the trout in the smaller of the two                    
             ponds and the catfish in the other pond.  At the time he                 
             purchased these fish, petitioner expected that he could                  
             sell the trout after they matured for somewhere between                  








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