Albert C. Johnson - Page 4

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          Issue 1.  Amount of Unreported Receipts From Cattle-Breeding                
               We first address the amount of petitioner's  unreported gross          
          receipts during the years 1990-93 from his cattle-breeding                  
               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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