River City Ranches #4 - Page 129




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          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.  Randy               






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