- 22 - 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.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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