- 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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