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match occurred after petitioners changed the tag number,
registration number, and breed information given in the original
bill of sale entry. The parties have stipulated exhibits in
evidence identifying the matches that respondent disputes falling
into these foregoing categories.
The parties’ above posttrial stipulations relate only to the
matching of registration certificates to petitioners' corrected
bills of sale for the partnerships. The parties agree that
neither petitioners nor respondent is to be precluded from
arguing that a partnership's breeding flock consisted of more or
fewer breeding sheep than the number of certificates matched.
A large unspecified number of the above 9,485 certificates
cover sheep that the Barnes family never sold to the
partnerships. In their above matching efforts, petitioners did
not attempt to identify and segregate breeding sheep that were
never sold to a partnership. For instance, none of the sheep
born in 1965 could possibly have been sold to a partnership, as
the first transaction between Barnes Ranches and one of the
partnerships occurred in 1981.
Discussion
Petitioners bear the burden of proving that respondent's
determinations in the FPAA's are incorrect. See Rules 142(a),
240(a); Welch v. Helvering, 290 U.S. 111 (1933). Particularly,
where respondent, as in the instant cases, has disallowed
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