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price of $5,080,000. He further claimed that the Schedule A to
one bill of sale (listing and identifying the specific 269
individual breeding cows the partnership purportedly acquired)
had been lost. In his testimony, Jay Hoyt further acknowledged
SGE 84-5's 1984 herd recap sheet (reflecting the partnership to
have purchased 693 breeding cattle during 1984) to be
inconsistent with the two April 1, 1984, bills of sale. However,
he asserted that Management’s practice, in preparing the herd
recap sheets for a cattle-breeding partnership’s first year of
operations, had been to reflect the net number of cattle later on
hand at yearend as the number of cattle a cattle-breeding
partnership purchased. He further specifically testified that
the prospective breeding cows SGE 84-5 was to purchase had been
identified in 1983 and that he reviewed a list of the cows in
early 1984. He added that between the April 1, 1984, purchase
date and December 31, 1984, some of the cows SGE 84-5 had
purchased possibly might have been lost, causing those cows not
to be reflected in SGE 84-5's 1984 herd recap sheet.
The Hoyt organization’s above-asserted “accounting practice”
is contrary to standard accounting principles because its herd
recap sheets show each partnership’s breeding herd to have had no
cattle born, no cattle culled, and no deaths or disappearances.
It is extremely unlikely that the breeding herd each of these
partnerships purportedly acquired would, in fact, have produced
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