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specific breeding sheep each partnership purportedly had
purchased. Mr. Hoyt was the managing general partner of each of
these partnerships, and he and his organization were responsible
for preparing each partnership's tax returns and maintaining its
records.17
C. Annual Flock Recap Sheets
On cross-examination by respondent's counsel, Mr. Hoyt was
asked to explain the inconsistency between the RCR #4 "finalized
bill of sale" dated February 1, 1984, listing 1,468 sheep (which
document, in fact, was prepared sometime after early 1986) and
the 1984 flock recap sheep reflecting the partnership had
acquired only 1,350 sheep during that year. Mr. Hoyt's
explanation was that, although RCR #4 acquired 1,468 animals on
February 1, 1984, it had suffered losses to its flock causing it
to have as of the end of 1984 the 1,350 animals reflected in the
flock recap sheet. He related that these losses to RCR #4's
flock were not reflected in the 1984 flock recap sheet because it
had been his and his organization's accounting practice, in
preparing an annual flock recap sheet for a partnership's first
17According to the testimony given by Mr. Barnes and Mr.
Hoyt, no other individuals besides themselves participated in
negotiating each partnership's transaction with Barnes Ranches.
They also failed to identify and name the Hoyt organization
employees who had prepared the bills of sale, and petitioners
offered no testimony from such employees regarding the
preparation of the bills of sale.
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