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eight of the partnerships (excluding OGT 90) a far greater total
number of specific individual breeding sheep than petitioners
have been able to match to registration certificates. Of the
total 9,361 breeding sheep entries in the bills of sale for these
eight partnerships, petitioners have been able to match just over
half to registration certificates.
Petitioners further acknowledge that there are significant
problems regarding specific individual sheep listed in the bills
of sale, and assert that numerous errors were made by the person
or persons who prepared the original bills of sale the
partnerships received. They further concede that from the
approximately 3,000 adult breeding sheep, respondent's expert Mr.
Clark counted during pretrial discovery (which are all the sheep
petitioners contend the nine partnerships owned by about 1992,
excluding another 2,600 commercial sheep the partnerships had
purchased from unrelated third parties in 1992), it is impossible
to trace and reconstruct the specific individual depreciable
sheep the partnerships owned during the years in issue.
Incidentally, petitioners did not specify how ownership of these
3,000 breeding sheep that Mr. Clark counted was specifically held
and divided up among each of the nine sheep partnerships.14
14In his testimony, Mr. Hoyt indicated that, as of the end
of 1991, the eight partnerships (excluding OGT 90) owned a total
of approximately 1,600 sheep and that OGT 90 owned approximately
(continued...)
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