- 44 - 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 693Page: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 Next
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