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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.
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