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(2) whether Waterfall Farms 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 the Hubers, as well as the principal place of business of
Waterfall Farms, was in Fulton, South Dakota.
A. The Hubers
The Hubers are husband and wife; they have three daughters.
The Hubers live in a house (the farmhouse) on 6 acres (the
homestead) that, until 1997, they leased from Emma Rose (Ms.
Rose). Between November 1989 and August 1992, the Hubers
acquired four contiguous lots totaling 330 acres (the Huber
farm). The Huber farm consists of farmland and pasture on which
the Hubers raise corn and livestock. There are no houses on the
Huber farm.
B. Waterfall Farms
The Hubers executed articles of incorporation for Waterfall
Farms on March 11, 1994.2 The articles were filed with the
2Douglas Bleeker, counsel for petitioners, prepared the
articles of incorporation, minutes of meetings, and other
(continued...)
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