- 28 - A. Whether DF #1, SGE 82-1, DGE 84-3, SGE 84-5, DGE 86-2, TBS 89-1, and TBS 90-1 Acquired the Benefits and Burdens of Ownership as to Specific Breeding Cattle For DF #1, SGE 82-1, DGE 84-3, SGE 84-5, DGE 86-2, TBS 89-1, and TBS 90-1 to be entitled to their claimed depreciation deductions, each partnership must establish that it acquired the benefits and burdens of ownership as to the specific individual breeding cattle making up its alleged breeding herd. In that connection, however, the record discloses petitioners to be in substantial difficulty in establishing that each partnership actually acquired anywhere near its stated number of breeding cattle. Indeed, the evidence petitioners presented to substantiate and identify the specific individual breeding cattle these partnerships “owned” is considerably lacking, exhibits major shortcomings, and, at times, is directly contradicted by the Hoyt organization’s own internal documents. Certain of these internal documents raise serious doubts in the Court’s mind as to whether large numbers of the breeding cattle allegedly sold these partnerships, in fact, existed. No registration papers with respect to specific breeding cattle were obtained in any partnership's name. Rather, any registration certificates reflect only the Hoyt family to be the owner of those registered cattle.14 14Unlike the parties in River City Ranches #4, J.V. v. Commissioner, T.C. Memo. 1999-209 (a case involving similar (continued...)Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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