Durham Farms #1 - Page 31




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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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