- 29 - 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 disallowedPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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