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(2) whether Dreyer 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 Weeldreyers, as well as the principal place of business of
Dreyer Farms, was in Bridgewater, South Dakota.
A. The Weeldreyers
The Weeldreyers are husband and wife; they have two sons.
Between September 1975 and April 1991, the Weeldreyers acquired
three contiguous tracts of land--two 80-acre tracts, one of which
included a house2 (the farmhouse), and a 160-acre tract. The
three tracts are referred to collectively as the Weeldreyer farm.
The Weeldreyers raise corn and soybeans on the Weeldreyer
farm. Their farming activities entail the planting, cultivation,
harvesting, drying, storage, and sale of corn and soybeans.
2The Weeldreyers have resided in the farmhouse since 1975.
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