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other documents purporting to evidence that sales of large
numbers of specific cattle had been made to these partnerships in
those years.8
During the litigation in Bales v. Commissioner, T.C. Memo.
1989-568, the Hoyt organization scheduled the “herds” of some of
the earlier partnerships the Hoyt family had formed (including
those “herds” of Florin Farms #3 (FF #3) and Florin Farms #4 (FF
#4)) to be liquidated during 1984 and 1985. In a memorandum
dated October 31, 1984, to his brother Ric Hoyt and other of the
Hoyt organization’s cattle managers, Jay Hoyt instructed them
that any cows they sold at certain public cattle sales during
1984 and 1985 would be attributed to specified partnerships, like
FF #3 and FF #4, to be liquidated. The memorandum also stated
that immediately before record ownership of such cows was
transferred to their buyers, “ownership” of the cows would be
assigned to FF #3 and FF #4. According to the memorandum, those
other partnerships “giving up” “their cows” to FF #3 and FF #4
8For example, in evidence are two bills of sale both dated
Apr. 1, 1984, that the Hoyt organization issued to SGE 84-5. One
bill of sale reflects SGE 84-5 to have acquired 500 breeding cows
with calves at side on that date for a stated price of
$5,080,000. The other bill of sale reflects SGE 84-5 to have
acquired 269 head of breeding cows on that date for a stated
price of $5,080,000. Also in evidence is a 1984 herd recap sheet
for SGE 84-5 that reflects the partnership to have purchased 693
breeding cattle during 1984.
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