- 71 - RCR #4 and RCR #6, had allegedly purchased from Barnes Ranches from 1981 through 1987, petitioners presented scant evidence to substantiate OGT 90's alleged 1990 purchase of individual breeding sheep from W.J. Hoyt Sons Ranches MLP. Petitioners submitted virtually no contemporaneous transactional documents and records for OGT 90. See supra note 9. The Court further does not find convincing Mr. Hoyt's explanation as to why no pertinent documents and records for OGT 90 could be produced.32 Thus we conclude that petitioners have failed to produce sufficient evidence substantiating OGT 90's claimed 1991 depreciation deduction with respect to the purported 1,301 breeding sheep" that it allegedly purchased during 1990.33 32In his testimony, Mr. Hoyt indicated that OGT 90's records and many records of the other partnerships were unavailable, because those records had been seized by postal inspectors from his organization's offices in 1995. However, the postal inspector who conducted the seizure testified that shortly after effectuating the seizure, he had provided Mr. Hoyt with an inventory of the seized documents. This postal inspector also related that, in response to Mr. Hoyt's and Mr. Hoyt's representatives' later requests, he had offered them access to the documents that had been seized. According to the postal inspector, Mr. Hoyt was also provided with copies of all the seized documents. 33Contrary to petitioners' contention, Mr. Barnes, on cross- examination, stated that he believed that Barnes Ranches had "sold" OGT 90 its "breeding sheep".Page: Previous 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 Next
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