River City Ranches #4 - Page 86

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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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Last modified: May 25, 2011