- 29 -
Petitioners further acknowledge that there are some problems
regarding the records they have offered in evidence to
substantiate the depreciation and other deductions claimed by the
partnerships. Petitioners also have indicated that the
depreciation deductions to which the partnerships are entitled
likely will be less than what the partnerships originally had
claimed.
On brief, however, petitioners argue that sufficient
breeding cattle existed in each year during the period from 1987
through 1992 to have been purchased by all of the cattle-breeding
partnerships the Hoyt organization formed (including by the seven
partnerships in the instant cases). Petitioners claim this has
been established by (1) the bills of sale and annual herd recap
sheets the Hoyt organization issued (which petitioners maintain
were accurate and contemporaneous documents)15 and (2) their
14(...continued)
sheep-breeding partnerships Jay Hoyt formed and operated), the
parties in the instant cases did not introduce in evidence
detailed information from numerous individual animal registration
certificates.
15On brief, petitioners further cite the cattle count
performed during the litigation of Bales v. Commissioner,
T.C. Memo. 1989-568, pursuant to which there were estimated to be
6,500 adult cows in the herds of 29 cattle-breeding partnerships.
The Court notes that this previous count was done in 1985.
Moreover, not all of the estimated 6,500 cattle were actually
examined and counted. Rather, cattle were counted in randomly
selected portions of 7 out of 26 fields or pastures. From the
250 to 400 cows counted in what was thought was a representative
sampling, a statistician extrapolated that there were a total of
(continued...)
Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 NextLast modified: May 25, 2011