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in evidence containing petitioners' corrected bills of sale for
these eight sheep partnerships. Petitioners' corrected bills of
sales for RCR #4 and RCR #6 are contained infra, respectively, in
Appendices B and C to this Memorandum Opinion. The parties,
however, disagree as to the number of actual breeding sheep that
RCR #4, RCR #6, and these other partnerships acquired from Barnes
Ranches.
Respondent examined petitioners' 4,839 matches and agrees
that there are 3,176 registration certificates which essentially
match entries on petitioners' corrected bills of sale. The
parties have stipulated an exhibit in evidence listing the
entries that respondent agrees the certificates essentially
match. Respondent, however, does not stipulate the existence of
any of the sheep described in this exhibit; respondent only
stipulates that 3,176 of the registration certificates
essentially match these listed entries from the corrected bills
of sale.
Respondent disputes petitioners' remaining 1,663 asserted
matches. Specifically, respondent claims: (1) As to 1,248 of
the remaining matches, petitioners matched the same registration
certificate to more than one bill of sale entry; (2) as to 300 of
the matches, other registration certificates show those same dams
as having given birth to another lamb less than 160 days prior to
having the matched animal; and (3) as to 115 of the matches, the
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