River City Ranches #4 - Page 118




                                       - 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  Next

Last modified: May 25, 2011