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Notwithstanding the above problems with the bills of sale
and flock recap sheets, petitioners argue that the stated number
of breeding sheep each partnership purportedly purchased and
depreciated actually existed. Petitioners assert that each
partnership did acquire beneficial ownership of its stated number
of breeding sheep on the date when that partnership and Barnes
Ranches had entered into their transaction. Petitioners claim
that this is established by the large number of matches
petitioners have been able to make between (1) certain
registration certificates and (2) petitioners' corrected bills of
sale for the partnerships. The Court disagrees.
Of the total 9,361 corrected bill of sale entries covering
specific breeding sheep that Barnes Ranches purportedly sold to
eight of the partnerships, petitioners have determined that 4,839
entries can be matched to registration certificates. However,
respondent agrees that only 3,176 of petitioners' corrected bill
of sale entries can be matched to a certificate. These 3,176
agreed matches are allocated among the eight partnerships as
follows:
Bill of Sale Agreed Cert.
Partnership Entries Matches
RCR #1 401 58
RCR #2 514 57
RCR #3 584 269
RCR #4 1,468 475
RCR #5 1,257 466
RCR #6 1,415 693
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