- 58 -
registered status of many of a partnership's sheep was suspect or
unknown.27 Consequently, the Court gives little weight to these
conclusions of these experts regarding the value of the
partnerships' sheep.
The record reflects that each partnership's stated purchase
price for its breeding sheep was still substantially in excess of
the prices the Barnes family, from 1981 through 1991, realized at
auction for the yearling Rambouillets and Suffolks they had
entered at various national shows.28 These yearling sheep
represented some of best young registered breeding sheep that the
Barnes family owned. Sales records show the Barnes family sold
such yearling sheep at auction for prices typically ranging from
$175 to $1,100, and that usually any sheep commanding a price of
$400 or more had been judged a champion or had won some other
award at that particular national show. Obviously, many of the
animals purportedly sold the partnerships were nowhere near the
quality of a purebred breeding sheep selling for $400 or more.
Indeed, the bills of sale listed substantial numbers of animals
27It is also to be noted that petitioners' experts examined
only the original bills of sale that Mr. Barnes issued (which
documents, petitioners have now acknowledged, contained numerous
"errors"), not the corrected bills of sale that petitioners
prepared after the trial. As discussed previously, however,
there are substantial problems even with these corrected bills of
sale.
28In this connection, Mr. Barnes testified that the breeding
sheep "sold" to the partnerships were usually yearlings.
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