River City Ranches #4 - Page 110




                                       - 48 -                                         
          than helping to reconcile and satisfactorily address these                  
          questions regarding the bills of sale, upon closer examination,             
          petitioners' posttrial matching efforts substantially diminish              
          their position that the stated numbers of specific breeding sheep           
          the partnerships purportedly purchased, in fact, existed.                   
               In the corrected bills of sale, included among the listed              
          breeding sheep that RCR #4 and RCR #6, respectively, purportedly            
          purchased from Barnes Ranches are large numbers of Rambouillets             
          and Suffolks reflected as being offspring of either (1) a                   
          Rambouillet dam having the registration number 772871 or (2) a              
          Suffolk dam having the registration number 772871.  Petitioners'            
          corrected RCR #4 bill of sale (see infra Appendix B) lists (1)              
          (a) 28 individual Rambouillets born in 1982 and (b) 37 individual           
          Rambouillets born in 1983, all of which Rambouillet breeding                
          sheep are shown as being the offspring of a Rambouillet dam,                
          registration number 772871, and (2) (a) 12 individual Suffolks              
          born in 1982 and (b) 33 individual Suffolks born in 1983, all of            
          which Suffolk breeding sheep are shown as being the offspring of            


               21(...continued)                                                       
          time, he also made rental arrangements to obtain the use of two             
          Treasure Valley rams.  One such ram was leased by him for 1 year            
          for $15,000; the second ram was leased by him for 1 year for                
          $10,000.  He also stated that none of the 15 Treasure Valley ewes           
          he purchased were resold to the partnerships.  In addition, it is           
          to be noted that the bill of sale document for OGT 87, dated Jan.           
          5, 1987, lists one Treasure Valley sheep and that the bill of               
          sale document for RCR #5-2, dated Feb. 1, 1987, lists two                   
          Treasure Valley sheep.                                                      





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