River City Ranches #4 - Page 94

                                       - 32 -                                         
          supra at 1237-1238; see also Cherin v. Commissioner, 89 T.C. 986,           
          996-997 (1987).                                                             
          A.  Whether RCR #4, RCR #6, and OGT 90 Acquired the Benefits and            
          Burdens of Ownership as to Specific Breeding Sheep                          
               For RCR #4, RCR #6, and OGT 90 to be entitled to their                 
          claimed depreciation deductions, each partnership must establish            
          that it acquired the benefits and burdens of ownership as to the            
          specific individual breeding sheep comprising its alleged                   
          breeding flock.  In that connection, however, the record                    
          discloses petitioners to be in substantial difficulty in                    
          establishing that each partnership actually acquired anywhere               
          near its stated number of breeding sheep.  Indeed, the evidence             
          petitioners presented to substantiate and identify the specific             
          individual breeding sheep these partnerships "owned" is                     
          considerably lacking, exhibits major shortcomings, and, at times,           
          is so flawed as to raise serious doubts in the Court's mind as to           
          whether large numbers of the breeding sheep allegedly sold these            
          partnerships, in fact, existed.                                             
               No registration papers with respect to specific breeding               
          sheep were obtained in any partnership's name.  The almost 9,500            
          registration certificates (accumulated by the Barnes family over            
          the years) in the record reflect only the Barnes family to be the           
          owner of those registered sheep.  Further, from 1981 through                
          1987, Barnes Ranches and the Barnes family purportedly sold to              

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