Washoe Ranches # 1, Ltd. Washoe Ranches #2, Ltd., Washoe Ranches #3, Ltd., Washoe Ranches #4, Ltd., Washoe Ranches #5, Ltd., Washoe Ranches #6, Ltd., Washoe Ranches #7, Ltd., Walter J. Hoyt III, - Page 12

                                       - 12 -                                         
          to depreciation for each year, and neither party has suggested a            
          different interpretation.  After considering these provisions and           
          the agreement as a whole, we reject petitioner's argument that              
          the provision limiting the number of depreciable cattle should be           
          read to limit the total number of cattle held by the                        
          partnerships.                                                               
               Even if we found the agreement ambiguous as to this                    
          provision, petitioner has offered no extrinsic evidence that                
          supports his position.  We find that the agreement limited the              
          number of cattle subject to depreciation only but did not limit             
          the number of non-depreciable cattle owned by the partnerships.             
               Petitioner further argues that the portion of the agreement            
          that provides that principal payments will begin in the sixth               
          year of the partnership should be enforced by concluding that               
          such payments are to be made by the transfer of registered                  
          shorthorn heifers.  The language of the agreement is silent as to           
          the method of payment.                                                      
               Petitioner's proffered evidence, when considered in light of           
          general contract principles, does not convince us that his                  
          interpretation is correct.  When the Court asked petitioner if he           
          assumed or intended that the provision meant that payment would             
          be made by the transfer of registered shorthorn heifers, he                 
          responded "I wouldn't characterize it that way".  He testified              
          that he did not designate, in the provision, the class of cattle            
          with which payment was to be made because he was focusing on                




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