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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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