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petitioners contend each partnership thereby acquired,10 and each
partnership's stated purchase price for its breeding sheep are as
follows:
Date of Number
Partnership Entry of Ewes Purchase Price
RCR #1 4-20-81 401 $455,100
RCR #2 2-15-82 514 626,400
RCR #3 3-20-83 584 713,140
RCR #4 2-1-84 1,468 2,087,880
RCR #5 5-1-85 1,257 1,825,000
RCR #6 1-15-86 1,415 1,960,140
OGT 87 1-5-87 1,849 3,636,000
RCR #5-2 2-1-87 1,873 3,982,000
In their respective sharecrop agreements, Barnes Ranches and
the above partnerships agreed that, in all registration papers
obtained with respect to a partnership's breeding sheep, the
Barnes family would remain the stated owners of those sheep.
However, each sharecrop agreement required Barnes Ranches to
maintain adequate records allowing it to identify at all times a
partnership's breeding sheep.
The respective bills of sale that Barnes Ranches issued to
the above partnerships are the exclusive purportedly
contemporaneous documentation in the record listing the specific
10The bills of sale issued to the partnerships, in fact,
list some rams as well as ewes. However, annual partnership
flock recap sheets (which are discussed more fully infra)
covering the respective years in which each partnership entered
into its sheep sale agreement, reflect only breeding ewes as
being initially acquired and owned throughout that year by a
partnership.
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Last modified: May 25, 2011