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individual breeding sheep each partnership purchased when it
entered into its transaction with Barnes Ranches. Each bill of
sale ostensibly identified all of the breeding sheep that
partnership purchased by listing and giving each individual
sheep's tag number, registration number, sex, breed, birth date,
sire's registration number, and dam's registration number.
However, as will be more fully discussed infra, petitioners have
subsequently acknowledged these bills of sale contained "numerous
errors".
As indicated previously, pursuant to the sheep sale
agreements, virtually all of the breeding sheep that these
partnerships (excluding OGT 90) acquired from Barnes Ranches were
supposed to be Rambouillet and Suffolk ewes.11 In addition,
substantially all of the breeding sheep these partnerships
acquired were supposed to be registered sheep. In point of fact,
most of the sheep that Barnes Ranches sold to each partnership
had not actually been registered with a national sheep breed
association.
11RCR #6's bill of sale, in fact, lists a very small number
of Hampshires as being acquired by that partnership. The record
does not disclose why RCR #6 would have wanted to purchase this
small number of Hampshires from Barnes Ranches. By the 1980's,
the Barnes family was concentrating on Rambouillets and Suffolks.
Further, in his testimony, Mr. Hoyt had related that each sheep
partnership's stated purpose and business was to produce
registered Rambouillets and registered Suffolks.
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