- 43 - partnership had entered already obligated Barnes Ranches to provide stud ram services to a partnership's breeding sheep. The Court considers the flock recap sheets Mr. Hoyt and his organization compiled highly suspect and unreliable, as Mr. Hoyt and his organization failed to employ good record keeping practices and appear to have prepared the recap sheets in a manner contrary to standard, fundamental accounting principles. The Court also can see no good reason or justification for their preparing these annual flock recap sheets in this highly deficient manner--if each of these partnerships, as petitioners maintain, indeed "owned" anywhere near the number of specific individual breeding sheep stated in its bill of sale. Indeed, the Court believes that the flock recap sheets were prepared in this manner because the requisite number of specific breeding sheep did not exist and could not, in fact, be assigned to each partnership. It is also to be noted that the flock recap sheets were, at times, inconsistent with the partnership returns Mr. Hoyt filed. For instance, the annual flock recap sheets reflect that RCR #3 had no breeding sheep by 1987. However, notwithstanding its apparently having no sheep, on its returns for the years 1987, 1988, and 1989, RCR #3 continued to claim and take farming expense deductions. D. Petitioners' Corrected Bills of SalePage: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 Next
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