- 31 - 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 22,148Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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