- 40 - 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.Page: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
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