- 18 - something in common that would make those cattle different from cattle assigned to other partnerships. He then suggested possible groupings the managers might use in assigning cattle among the partnerships, including common sires, common grandsires, common cow families, just bulls, just females, ASA appendix registry cattle, full blood cattle, etc. C. Transactional Documentation Relating to the Seven Cattle- Breeding Partnerships’ Purchases of Cattle From 1987 Through 1992 The record contains almost no transactional documentation relating to DF #1’s, SGE 82-1’s, DGE 84-3’s, SGE 84-5’s, DGE 86- 2’s, TBS 89-1’s, and TBS 90-1’s purchases of breeding cattle during 1987 through 1992. Unlike Bales v. Commissioner, T.C. Memo. 1989-568,12 among other things, there is no (1) bill of sale issued by Ranches or its successors to each of the seven cattle-breeding partnerships listing and identifying the individual breeding cattle sold to each partnership, (2) ?Full Recourse Promissory Note” issued by each partnership for its cattle, and (3) sharecrop agreement between Management and each partnership. The record contains documentation relating only to transactions some of these seven partnerships entered into before 1987. The record also includes certain annual herd recap sheets the Hoyt organization issued concerning the breeding cattle of 12See also River City Ranches #4, J.V. v. Commissioner, T.C. Memo. 1999-209 (involving similar sheep-breeding partnerships Jay Hoyt organized and operated).Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
Last modified: May 25, 2011