Ronald D. Weeldreyer and Suzanne Weeldreyer - Page 3

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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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