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(2) whether Wolf Creek Farm is liable for the accuracy-
related penalty under section 6662(a) for the taxable years ended
November 30, 1995, 1996, and 1997.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
When the petitions were filed in these cases, the residence
of Mr. Tschetter, as well as the principal place of business of
Wolf Creek Farm, was in Bridgewater, South Dakota.
A. Mr. Tschetter
Mr. Tschetter has lived with his parents his entire life
(approximately 47 years). The family residence (the farmhouse)
has been in the Tschetter family for over 70 years. On or about
July 7, 1993, Mr. Tschetter’s parents gave him the farmhouse and
79 acres of farm land on which the farmhouse is located (the
homestead).
Since 1988, Mr. Tschetter has owned another 156 acres (the
Tschetter farm). The Tschetter farm is approximately 1 mile from
the homestead.
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Last modified: May 25, 2011