Robert E. and Carloyn S. Holmes - Page 17

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             Additionally, petitioners planted soybeans on 13.1 acres                 
             and harvested 126 bushels.  Petitioners did not plant or                 
             harvest any oats during 1989.  Although petitioners did not              
             report any gross income from the sale of corn in 1989, they              
             did report $2,000 as gross income from the sale of hay and               
             straw.                                                                   
                  Petitioners planted 11.1 acres of corn in 1990,                     
             producing a total harvest of 164 bushels.  Petitioners                   
             did not plant or harvest any soybeans or oats in 1990.                   
             Petitioners reported gross income from the sale of corn in               
             1990 of $2,927.  Petitioners did not plant any row crops                 
             on their property during 1991 or 1992, but they reported                 
             gross income of $1,729 from the sale of miscellaneous                    
             livestock and produce in 1991.                                           
                  The average corn yields for farms in Calhoun County,                
             Michigan, and petitioners' average corn yields during the                
             years in issue are as follows:                                           

                                    Average        Petitioners' Average               
                      Year       Bushels/Acre      Bushels/Acre                       
                      1987           79.1                 38.09                       
                      1988           56.9                  --                         
                      1989           112.1                48.26                       
                      1990           119.4                14.78                       
                      1991           94.9                  --                         









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