- 33 - 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...)Page: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
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