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partnerships purchased. Their several experts opined with
respect to (1) the high quality of some of the breeding sheep the
Barnes family owned and (2) Mr. Barnes' and Randy's status in
this country as top breeders of Rambouillets and Suffolks. These
experts then further opined and concluded that the values the
bills of sale placed on individual breeding sheep were
reasonable.
Petitioners' experts furnished little in the way of analysis
or explanation of their conclusions concerning the value of the
sheep allegedly sold the partnerships. Further, they were basing
their opinions upon their prior exposure to only a limited number
of the Barnes family's sheep, primarily those sheep the Barnes
family had either (1) entered in various national shows or (2)
employed various artificial insemination techniques upon. As
they had never examined the sheep that purportedly were sold to
the partnerships, the experts merely assumed each partnership's
sheep to be like these other very high quality sheep they knew
the Barnes family to own. As a result, none of petitioners'
experts anticipated the sheep sold the partnerships were anything
other than high quality, registered Rambouillets or high quality,
registered Suffolks. They further never addressed how
drastically their opinions might have to be revised if (1) a
large number of the breeding sheep a partnership purportedly
purchased did not, in fact, exist, or (2) the parentage or
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