River City Ranches #4 - Page 106




                                       - 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          693                                 






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

Last modified: May 25, 2011