George R. and Barbara H. Burrus - Page 4

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          in Africa, during which time he established a small missionary              
          hospital that remains in operation today.  Petitioners return to            
          Africa to work at the hospital twice a year, for a month each in            
          the spring and fall.                                                        
               In 1978, Dr. Burrus entered into a partnership, the Foreman-           
          Burrus Hereford Ranch (FBHR), with a fellow physician, Howard               
          Foreman (Dr. Foreman), to breed purebred horned Hereford cattle.            
          Initially, Drs. Burrus and Foreman shared FBHR’s profits and                
          losses equally.                                                             
               In 1980, FBHR acquired 505 acres of property in Cheatham               
          County, Tennessee (Cheatham Property), comprising three separate            
          tracts of land.  The Cheatham Property was purchased at $1,200              
          per acre for a total purchase price of $606,000.  Drs. Burrus and           
          Foreman chose this property for FBHR because of its proximity to            
          Nashville and their medical practices.                                      
               At most times, FBHR was operated by five ranch hands and               
          maintained up to approximately 250 animals.  Cattle were bred by            
          FBHR by means of an “embryo transfer” method, which at the time             
          was a technique of surgically implanting embryos in cows.1  After           
          FBHR incurred losses for the first 5 or 6 years of its existence,           
          Dr. Burrus became concerned that the operation could not be run             


               1 Embryo transfer was subsequently perfected as a less                 
          expensive, nonsurgical technique.                                           




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