Gary G. and Linda J. Hart - Page 3

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          limited amount of corn and hay to feed their cattle.  During the             
          year in issue, petitioners grew approximately 50,000 pounds of               
          tobacco on their farm.  Petitioners also purchase, and make ready            
          for market, tobacco crop from tobacco farmers who do not                     
          themselves process the tobacco.                                              
               To make their tobacco ready for market, petitioners process             
          the tobacco in the following manner:  Petitioners generally                  
          harvest their tobacco crop at the end of July.  The cut tobacco              
          is then mounted over approximately 4-foot-long sticks, six to                
          eight plants on a single stick.  The tobacco is then left in the             
          field for a few days for field curing; i.e., drying.  Thereafter,            
          the tobacco is loaded onto wagons and transported to a tobacco               
          barn.  In the tobacco barn, the tobacco sticks are hung on                   
          stringers and left to cure for several months, generally until               
          October.  Petitioners hire a "few" employees for about 6 weeks to            
          assist them with the aforementioned tasks.                                   
               After curing their tobacco, petitioners strip the tobacco               
          leaves from the stalk and grade them into 3 to 4 different                   
          qualities.  Stripping and grading of the tobacco leaves are                  
          essential parts of petitioners' tobacco business.  Finally,                  
          petitioners bale the graded tobacco leaves, put them into boxes,             
          and transport them to another location where they are eventually             
          shipped to the market.  Petitioners hire a "few" employees,                  
          generally for about 5 months, to assist them with the stripping,             
          grading, baling, and boxing of the tobacco leaves.                           

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