- 56 -
For the breeding flock it purportedly acquired from Barnes
Ranches, each partnership agreed to pay an average stated price
per sheep as follows:
Total Stated Number of Avg. Price
Partnership Sales Price Sheep in Flock per Sheep
RCR #1 $455,100 401 $1,135
RCR #2 626,400 514 1,219
RCR #3 713,140 584 1,221
RCR #4 2,087,880 1,468 1,422
RCR #5 1,825,000 1,257 1,452
RCR #6 1,960,140 1,415 1,385
OGT 87 3,636,600 1,849 1,967
RCR #5-2 3,982,360 1,873 2,126
Petitioners contend the breeding sheep the partnerships
purchased had values ranging from $500 to $2,130, and that the
total stated purchase price each partnership paid was reasonable.
In doing so, they are essentially asserting the Court should
accept as correct the values placed on various individual
breeding sheep in the bills of sale that Barnes Ranches issued
these partnerships, despite the "substantial errors" that
petitioners have now acknowledged were made in these bills of
sale.
Respondent, on the other hand, contends that during 1981
through 1991, registered breeding sheep sold for amounts
substantially below the values stated in these partnerships'
bills of sale. The Court essentially agrees with respondent.
Petitioners offered only very generalized and vague expert
testimony regarding the value of the breeding sheep the
Page: Previous 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 NextLast modified: May 25, 2011