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Respondent concedes that these amounts should be given capital
gains treatment.
Petitioner’s farming operation also included the planting
and harvesting of corn during the years 1989 through 1992. On
August 21, 1990, Ag Max, a grain elevator that buys and sells
grain, issued a $17,208.11 check to Tadd Hoover and Michael
Hoover for the purchase of 6,104.42 bushels of petitioner’s corn.
From 1989 through 1992, petitioner stored corn at, and
bought cattle feed from, Roann Farm Center, Inc. (Roann), a grain
elevator and feed operation in Wabash, Indiana. Petitioner
maintained his corn inventory held in storage with Roann in the
name of Michael Hoover or Tadd Hoover. Roann paid petitioner
$7,680 on April 25, 1990, $17,500 on April 15, 1991, and $6,200
on February 4, 1992, for shelled corn. These payments were made
by checks payable to Michael Hoover in 1990, Tadd Hoover in 1991,
and petitioner in 1992.
Petitioner’s brother, Fred Hoover, also engaged in farming.
Fred Hoover rented farm land from petitioner during the years in
issue. Fred Hoover paid rent to petitioner of $10,500 in 1990,
$2,475 in 1991, and $2,475 in 1992.
Petitioner and Fred Hoover also practiced a bartering system
in which they exchanged goods and services. Fred Hoover
maintained an account of debts due to and owed by petitioner
during the years in issue. These records reflect that Fred
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