LOKEN, Circuit Judge.
Horace and Donna Walter farm and feed cattle in rural Clark County, South Dakota. By 1985 and 1986, the tax years in question, they were feeding and selling over 8,000 cattle per year and farming about 2,000 acres. In their joint federal income tax returns for those years, the Walters reported taxable income of $195,353 in 1985 and $204,513 in 1986. In 1988, the Commissioner of Internal Revenue audited the returns, increasing the Walters' taxable...
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