Durham Farms #1 - Page 55




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          purportedly purchased and owned by all of the cattle-breeding               
          partnerships.  See Rules 142(a), 240(a).  Indeed, the 1987 bills            
          of sale in evidence (which the Court previously determined were             
          highly suspect and unreliable) reflect 26 newly formed                      
          partnerships alone to have purportedly purchased over 13,000                
          breeding cattle during that year.                                           
               E.  Whether a Partnership’s Stated Purchase Price Reasonably           
          Approximated the Cattle’s Fair Market Value                                 
               Petitioners contend that the breeding cattle each                      
          partnership acquired from the Hoyt organization had a value of              
          $4,000 per animal and that the total stated purchase price each             
          partnership paid for its breeding cattle was reasonable.                    
               Respondent, on the other hand, contends that during the                
          years relevant to the instant cases, the Hoyt organization’s                
          breeding cattle had a value substantially below $4,000 per                  
          animal.  The Court essentially agrees with respondent.                      
               In asserting their $4,000 per animal valuation, petitioners            
          rely heavily on the testimony of their expert Mr. Hunsley.  Mr.             
          Hunsley has been the ASA’s executive director since about 1983              
          and was also an expert witness for the taxpayers in Bales v.                
          Commissioner, T.C. Memo. 1989-568.  Although Mr. Hunsley had not            
          examined the specific individual cattle the partnerships in the             
          instant cases purportedly purchased and owned, he claimed to have           
          seen a number of cattle in the Hoyt organization herd over the              
          years, including at cattle shows and on visits he made to certain           





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