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registered 62 Hereford cattle. However, respondent’s expert does
not further discuss this reference, suggesting to us that his
report lacked either thoroughness or objectivity. Respondent’s
expert further testified that embryo transfer would have been
used in a profitable operation, whereas petitioner’s expert
testified that a switch from embryo transfer to natural selection
in 1990 would have been a valid business decision at the time,
given the then high cost of embryo transfer. Finally,
respondent’s expert postulated that for-profit purebred cattle
breeding operations would be conducted at a well maintained,
aesthetically pleasing farm site that would conform to the
expectations of customers visiting the site for on-site
purchases. The expert found Maple Row’s facilities deficient in
this respect and also believed that a for-profit operation would
engage in advertising to attract such on-site customers. In
fact, Maple Row sold its cattle by means of off-site auctions,
obviating the need for advertising, and the prices petitioners
obtained at auction were in line with what respondent’s expert
indicated were market prices. In sum, we are not persuaded that
Maple Row’s variances from the model cattle operation postulated
by respondent’s expert suggest a lack of profit motive.
Overall, we are persuaded that petitioners conducted their
cattle breeding activity in a businesslike manner and maintained
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