- 16 -
years 1980 through 1986. This exhibit is not considered to be
evidence. Rule 143(b). Petitioner also argues that the
stipulations entered in another case are evidence in support of
his position. Stipulations have effect in the cases only in
which they are entered and are not binding for any other purpose.
Rule 91(e). Therefore, the stipulations from the other cases are
not evidence in these cases.
Petitioner has offered no other evidence to show that any
cash was paid to Hoyt & Sons Ranches. The only evidence
introduced by petitioner are the bills of sale detailing the
number of cattle transferred as payment on the notes. Moreover,
petitioner stipulated that the payments at issue were made by
transferring cattle, not cash. This stipulation is not clearly
contrary to the facts disclosed on the record. Therefore, we
find that the partnerships made interest and principal payments
beginning in the sixth year of the notes payable by transferring
cattle. They must recognize ordinary income on the transfer of
cattle in the amounts stipulated.
To reflect the foregoing,
An appropriate order and decision
will be entered in each case.
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