- 55 - 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 certainPage: Previous 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 Next
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