George R. and Barbara H. Burrus - Page 9

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          listed the Maple Row cattle that were registered with the AHA and           
          their registration numbers.  Based on the herd inventory records,           
          Maple Row’s cows produced the following offspring in the years              
          indicated:                                                                  
                         Year      Heifers   Bulls     Total                          
                         1990      13        6         19                             
                         1991      10        7         17                             
                         1992      15        15        30                             
                         1993      17        20        37                             
                         1994      27        24        51                             
                         1995      30        23        53                             
          In 1998, two of the cows in the Maple Row herd received “Dam of             
          Distinction” awards from the AHA for exceeding certain calf                 
          production standards as measured against other cows in the herd.            
          One cow had produced nine calves and the other six.                         
               Although petitioners did not have a written business plan              
          for Maple Row, Dr. Burrus anticipated that the cattle operation             
          would begin to show a profit once his herd reached 100                      
          “productive”–-i.e., calf-bearing-–cows.  Dr. Burrus anticipated             
          selling the male offspring at the age of 2 for approximately                
          $2,000 each, as well as a small number of culled females while              
          retaining the remaining females to build the herd.                          
               The primary financial record maintained in connection with             
          Maple Row was a ledger used to record the activity occurring in             
          the three bank accounts petitioners maintained for the purpose of           






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