- 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 thePage: Previous 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 Next
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