Jere J. and Paulette M. Solvie - Page 3

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               Prior to 1991, Mr. Solvie participated in the management of,           
          and in all phases of, crop production and animal production by              
          performing, inter alia, the following farm-related activities in            
          the production of agricultural commodities (i.e., hogs):  Loading           
          of the hogs; washing the facilities; checking the feed lines and            
          water levels; refilling the feed lines when necessary; and                  
          observing hogs for disease.  Prior to 1991, Ms. Solvie performed            
          the following farm-related activities in the production of                  
          agricultural commodities:  Entering data into the bookkeeping               
          system; accounting; conferring with accountants about bookkeeping           
          and return preparation; picking up orders and spare parts; and              
          running errands.  Prior to 1991, the farming operation had the              
          capacity to process 1,000 head of hogs.                                     
               In December 1991, petitioners formed JJ & P Farms, Inc.                
          Petitioners each owned 50 percent of the stock of JJ & P Farms,             
          Inc., and they comprised the board of directors (board) of that             
          company.  At all relevant times, JJ & P Farms, Inc., engaged in             
          the farming business, specifically raising hogs for the produc-             
          tion of pork.  During 1993, 1994, and 1995, JJ & P Farms, Inc.,             
          farmed the same 928 acres of land that petitioners had farmed               
          prior to 1991, 415 acres of which petitioners owned.  Third                 



               3(...continued)                                                        
          edges that that stipulation is not accurate and that third                  
          parties owned 513 acres.                                                    




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