Durham Farms #1 - Page 22




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          identifying the individual animals a partnership had allegedly              
          purchased.  The bills of sales for these 21 partnerships                    
          reflected them to have collectively purchased more than 10,000              
          breeding cattle during 1987.  Similarly, certain 1991 herd recap            
          sheets respondent received reflected 18 partnerships, including             
          DGE 86-2, as each purchasing 500 to 600 breeding cows during                
          1991.  For instance, the 1991 herd recap sheet for DGE 86-2                 
          reflects the partnership to have purchased 545 breeding cows                
          during 1991.13                                                              
               During the examination, respondent issued numerous                     
          administrative summonses to the cattle-breeding partnerships and            
          certain entities in the Hoyt organization, pursuant to which                
          respondent sought information and documents relating to the                 
          cattle breeding partnerships’ alleged cattle purchases from the             
          Hoyt organization.  Among other things, respondent sought to                
          inspect and count the breeding cattle allegedly purchased and               
          owned by the cattle-breeding partnerships.  The Hoyt organization           


               13As indicated previously, the record contains no bills of             
          sale 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.  Indeed, the revenue agent who examined           
          the returns covering the period from 1987 through 1992 of all the           
          cattle-breeding partnerships the Hoyt organization had formed               
          (including the returns of the seven partnerships involved in the            
          instant cases) testified that no bills of sale were provided to             
          respondent for any breeding cattle purchases any of the                     
          partnerships allegedly made from 1988 through 1991.  Yet, in his            
          testimony, Jay Hoyt claimed that all of the bills of sale                   
          relating to the partnerships’ alleged breeding cattle purchases             
          from 1988 through 1992 had been provided to respondent.                     





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