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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.
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