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B. The Bills of Sale and Herd Recap Sheets Issued by the
Hoyt Organization
As indicated previously, petitioners argue that various
bills of sale and annual herd recap sheets the Hoyt organization
issued substantiate the depreciation deductions on breeding
cattle being claimed for the years in issue in the instant cases
by DF #1, SGE 82-1, DGE 84-3, SGE 84-5, DGE 86-2, TBS 89-1, and
TBS 90-1.17 They maintain that these bills of sale and herd
recap sheets are reliable and contemporaneous documents
evidencing the alleged specific individual breeding cattle each
partnership purportedly purchased and owned from 1987 through
1992. In making this contention, petitioners heavily rely on the
testimony of Jay Hoyt.
Jay Hoyt specifically testified that the bills of sale and
annual herd recap sheets the Hoyt organization issued to the
cattle-breeding partnerships were reliable and contemporaneous
documents. Although he acknowledged occasional but inadvertent
17In their brief, petitioners contend that the annual herd
recap sheets in evidence reflect that, collectively, all of the
cattle-breeding partnerships (which in some years may have
included perhaps almost 100 separate partnerships) owned the
following total numbers of cattle on the dates indicated:
Date Total Number of Cattle
1-1-87 22,457
1-1-88 25,613
1-1-89 23,418
1-1-90 17,336
1-1-92 22,148
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