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$200,000 in 1990 and $400,000 in 1995, and the Sumner Property’s
value at $316,000 in 1990 and $700,000 in 1995.
Petitioners employed Charles Gruen, who had worked for FBHR
before its dissolution, as the sole ranch hand at Maple Row from
1990 until he retired in 2000. Mr. Gruen, who had experience
working with cattle for about 20 years before joining FBHR, was
placed in charge of Maple Row’s day-to-day operations. Dr.
Burrus and Mr. Gruen communicated frequently, often daily,
regarding operations at Maple Row. Mr. Gruen resided with his
wife at the Cheatham Property.
Rather than selling cattle on location at the Cheatham
Property, as was done by FBHR, Maple Row’s livestock sales,
principally purebred Hereford bulls, were made at “absolute”
auctions in Montgomery, Alabama, and Orlando, Florida. Dr.
Burrus did not advertise regarding Maple Row’s livestock during
the years in issue.
Petitioners’ herd inventory records were maintained by Mr.
Gruen and consisted of two parts. The first was the “Office
Copy of Breeding and Calving Record”, which contained information
regarding the cattle in the Maple Row herd including their
parentage, birth date, birth weight, and identification number
that was submitted to the American Hereford Association (AHA).
The second record was the “Herd Performance Enrollment”, which
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Last modified: May 25, 2011