- 12 - during the period from 1987 through 1992. The record in the instant cases reflects that many of the documents, records, and tax returns the Hoyt organization prepared relating to its transactions with the cattle-breeding partnerships it formed are inaccurate and unreliable. For instance, the cattle-breeding partnerships the Hoyt organization formed in 1983, 1984, 1985, and 1986 had no specific breeding cattle assigned to them even as of 1987.6 This is reflected in a report the Hoyt organization prepared with respect to the 1986 operating results of cattle-breeding partnerships it had formed. This report, dated December 31, 1986, states that no operating results were reported on cattle- breeding partnerships formed in 1983, 1984, 1985, and 1986 because those partnerships were still “in the process of forming their breeding herds * * * [in a selection process] which 6Each of the breeding cattle a partnership acquired was supposed to be listed and identified in the bill of sale Ranches issued that partnership. According to Jay Hoyt, the Hoyt organization’s original practice had been to attach copies of all the animals’ registration certificates to the bill of sale. He further indicated that after the Hoyt organization’s cattle records were computerized around 1985, a Schedule A containing all of this same information (including each individual animal’s tag number, registration number, birth date, and sex, as well as the respective registration numbers of its sire and dam) was instead prepared and attached to the bill of sale. In addition, although the sharecrop agreement that Management and a cattle- breeding partnership entered typically recognized that any registration papers on a partnership’s breeding cattle would be taken out in the Hoyt family’s name, the sharecrop agreement required Management to know the identity and number of a partnership’s breeding cattle at all times.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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