- 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).
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