River City Ranches #1 Ltd., Leon Shepard, Tax Matters Partner - Page 72

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          California.  The record establishes that any sheep that actually             
          existed were located on Barnes Ranch in Sacramento, California.              
          In addition, for all the years at issue, the record shows that               
          the checks from individual sheep partners were received at the               
          Elk Grove, California, office and deposited into the RCR account             
          or the pooling account at the bank located in Elk Grove,                     
          California.                                                                  
               While the record contains evidence that money was deposited             
          into bank accounts in California during the years at issue, no               
          evidence was presented showing that the money ever left                      
          California.  There is no evidence in the record to establish that            
          any of the investor funds were ever transferred to the Hoyt                  
          office in Burns, Oregon, or deposited into an Oregon bank account            
          during any of the years at issue.  Further, petitioners failed to            
          present any evidence that any partnership property was illegally             
          taken from anywhere in Oregon during any of the years at issue.              
               Without any evidence to link the investor funds to Oregon,              
          petitioners cannot possibly prove that Oregon is the jurisdiction            
          where the alleged thefts occurred.  Therefore, due to the lack of            
          evidence presented on this issue, petitioners have failed to                 
          establish that a theft of partnership property occurred within               
          the State of Oregon during any of the years at issue.  However,              
          in light of Jay Hoyt’s criminal activities in Oregon, we shall               
          analyze the three Oregon statutes cited by petitioners to                    






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