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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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