River City Ranches #4 - Page 95

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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            

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