- 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 toPage: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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