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Issue 1. Amount of Unreported Receipts From Cattle-Breeding
Operation
We first address the amount of petitioner's unreported gross
receipts during the years 1990-93 from his cattle-breeding
operation.
Petitioner was employed by Stouffer Chemical until 1986 when
he became disabled and began receiving disability and Social
Security benefits. In 1989, he began to supplement his disability
benefits by breeding and raising Belgian blue cattle. Belgian blue
cattle are a unique breed: originally imported from Belgium, they
have a high meat to bone ratio and are low in fat and cholesterol.2
(Belgian blue cattle are even lower in fat and cholesterol than
skinless chicken breast.)
Petitioner first became interested in Belgian blue cattle as
a consequence of his being (in his words) "overweight" (360 pounds)
and having suffered several heart attacks. He wished to raise
healthy meat for his own personal consumption, as well as to
promote the breed so that others similarly situated could enjoy
low-fat beef.
Petitioner purchased his first heifer from agents of Philip
Stennett in 1989, and since that time petitioner has maintained
about 10 cows on his 24-acre farm in Fairview, Tennessee. Mr.
2 Following World War II, the Belgian Government sought
to produce cattle with a high ratio of meat to feed its people
following their freedom from occupation.
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