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issued by Mr. Hoyt in connection with each partnership's
promissory note, and (4) a sharecrop agreement between Barnes
Ranches and each partnership. The record does not include a
written sheep sale agreement between Barnes Ranches and RCR #4 or
a written sheep sale agreement between Barnes Ranches and RCR #6,
offering memoranda for either partnership, or a partnership
agreement for RCR #6.
A bill of sale dated February 1, 1984, that Barnes Ranches
issued ostensibly lists and identifies the 1,468 specific
individual breeding sheep petitioners contend Barnes Ranches
transferred to RCR #4 pursuant to their sheep sale agreement of
that same date. A bill of sale dated January 15, 1986, that
Barnes Ranch issued ostensibly lists and identifies the 1,415
specific individual breeding sheep Barnes Ranches transferred to
RCR #6 pursuant to their sheep sale agreement of that same date.
Substantially, all of this same information concerning specific
individual sheep that RCR #4, RCR #6, and other partnerships
purchased from Barnes Ranches is summarized in the corrected
bills of sale that petitioners later prepared and submitted in
evidence following the trial in the instant cases. Petitioners'
corrected bills of sale are discussed more fully infra.
The RCR #4 promissory note for $2,087,880 dated February 1,
1984, that Mr. Hoyt issued to Barnes Ranches was stated to be a
"Full Recourse Promissory Note". The note further stated that
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