River City Ranches #4 - Page 102

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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            
          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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