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Mr. Truskowsky commuted to central New Jersey from Trappe,
Pennsylvania, every day.
Petitioners' Cattle Breeding Activity
Petitioners' cattle breeding activity began in 1994, when
they bought their first cows. They were "Limousin" cattle, a
beef breed from France. Petitioners decided to go into the
Limousin cattle business after considering other breeds of
cattle.
The Farm
Petitioners needed a place to board their cattle as they did
not own a farm during the years in issue. Petitioners learned
about K-C Delight Farm (K-C) from a local newspaper that
advertises to farmers. They visited K-C and other farms before
choosing K-C. Chester Deitch, who operated K-C, did not own the
farm, but rented it. He operated K-C primarily as a "multiple
acreage" general and dairy farm. Near his home and included in
Mr. Deitch's farmland rental was a parcel of land where he
boarded petitioners' cattle. Mr. Deitch maintained approximately
two dozen cattle of his own on the same parcel where he boarded
petitioners' cattle. Mr. Deitch maintained his and petitioners'
animals in different paddocks. Petitioners' animals had their
own shelter and automatic watering systems.
Mr. Deitch did not live on the parcel of property where he
kept petitioners' cattle, at 117 Simmons Road. There were,
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