Durham Farms #1 - Page 18




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          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).                                               





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