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numbers”. Instead, as reflected by the worker’s questions to Jay
Hoyt and Jay Hoyt’s responses (which we have previously noted), a
far different process was employed to prepare Management’s 1989
and 1990 fiscal year financial statements.18
The Court would further note (as was stated supra) that the
record includes none of the bills of sale that purportedly were
issued to cattle-breeding partnerships from 1988 through 1992,
notwithstanding that a number of these partnerships (including
several of the seven cattle-breeding partnerships in the instant
cases) reported on their tax returns purchasing breeding cattle
during this period for which they are claiming deductions. A
revenue agent for respondent testified that no bills of sale for
any cattle-breeding partnerships were furnished for years after
1987. Yet, Jay Hoyt testified that he provided to respondent
such bills of sale for the years from 1988 through 1992.19
18It is further to be noted that following Mr. Favre’s
completion of his cattle count in about spring 1993 (which count
was mentioned supra note 16, and is discussed in more detail
infra), Jay Hoyt, in a memorandum dated Oct. 1, 1993, instructed
the Hoyt organization’s cattle managers to prepare herd recap
sheets for the cattle-breeding partnerships up through Dec. 31,
1992. See supra note 17.
19We do not find to be credible this and other similar
assertions of Jay Hoyt regarding these bills of sale. Respondent
had been requesting them from Jay Hoyt, the cattle-breeding
partnerships, and the Hoyt organization since at least about 1992
(when respondent actively started examining many of the returns
filed by the partnerships and certain Hoyt organizations for the
years covering the 1987 through 1992 period). Jay Hoyt testified
these alleged 1988 through 1992 bills of sale had been provided
(continued...)
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