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In addition, the record reflects other highly unusual
conduct by the Barnes family and Mr. Hoyt with respect to these
alleged recourse partnership debts. As previously discussed, the
sharecrop agreements provided that a partnership would still
retain the breeding value certificates (i.e., the rights to any
registration papers obtained) on male lambs produced by its
breeding flock, even though, pursuant to the sharecrop agreement,
all male and female lambs produced were to belong to Barnes
Ranches as compensation for its services. Mr. Hoyt claimed that
the partnerships, over the years, did sell some of their breeding
value certificates to the Barnes family, and that each
partnership reported large sums from selling such certificates on
its partnership returns. He related that he and Randy at the
beginning of each year typically negotiated these breeding value
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