- 67 - certificate transactions, as Randy would need to obtain the registration paper rights held by certain partnerships on particular male sheep he contemplated selling later that year at various annual shows. Mr. Hoyt specifically testified that RCR #4, on its 1989 or 1990 return, reported $260,000 of income from its sales of breeding value certificates, and that RCR #6, on one of its later returns, reported about $500,000 of income from its sale of breeding value certificates. He stated the certificate proceeds were applied against the first principal payments that RCR #4 and RCR #6 each owed to Barnes Ranches under their respective "recourse promissory notes". He added that up to that point, the partnerships had not been reporting annually the income from their sales of breeding value certificates. Thus, the respective $260,000 or $500,000 of income that each partnership reported, for its fifth or sixth year of operation, also included some accumulated income each partnership had derived in prior years from selling breeding value certificates. Although Randy did state that he and Mr. Hoyt, over the years, had negotiated the Barnes family's purchase of breeding value certificates held by the eight partnerships (excluding OGT 90, which petitioners contend did not enter into a transaction with Barnes Ranches), his testimony differed from and contradicted that of Mr. Hoyt's in important respects. RandyPage: Previous 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 Next
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