- 24 - In their respective petitions or amended petitions, RCR #4, RCR #6, and OGT 90 claimed certain additional deductions for the years in issue. The total depreciation and other deductions claimed by them now in issue are given infra in Appendix E to this Memorandum Opinion. During either the examinations respondent conducted of the nine sheep partnerships' returns or pretrial discovery, petitioners provided respondent with respective bills of sale that Barnes Ranches issued to each partnership (excluding OGT 90), listing all of the individual sheep a partnership had purchased. Although petitioners first provided respondent with a bill of sale document for RCR #4 listing 1,350 sheep, petitioners eventually provided respondent with a second bill of sale document for RCR #4 listing 1,468 sheep. The individual sheep this second RCR #4 bill of sale document lists are quite different from those listed in the first RCR #4 bill of sale document that originally had been provided to respondent by petitioners. Petitioners contend the second document was the actual bill of sale issued on February 1, 1984, to evidence and reflect Barnes Ranches' transfer to RCR #4 of the 1,468 individual sheep described and listed thereon. As indicated previously, however, this second document was prepared well after its stated date of February 1, 1984.Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
Last modified: May 25, 2011