- 8 - organization from 1982 through 1998 by investor-partners in various investor partnerships, including the partnership RCR #1. RCR #1, which had been organized and promoted by Mr. Hoyt as a sheep breeding partnership, had begun operating in 1981. Mr. Hoyt was responsible for and directed the preparation of RCR #1's partnership income tax return for 1981, although he may not have prepared the return personally. Barnes Ranches was a sheep breeding business owned and operated by David Barnes and April Barnes. David Barnes had experience in breeding several breeds of purebred sheep, including Hampshires, Rambouillets, and Suffolks. Randy Barnes, who had acquired a degree in agricultural business management in 1985, began working for Barnes Ranches in that year to handle the sheep breeding and feeding programs. By the late 1980's, David Barnes, along with Randy Barnes, had acquired very good reputations in purebred sheep breeding circles and were generally considered to be among the country’s top breeders of Rambouillet and Suffolks. During the 1980s, Barnes Ranches typically would enter annually from 20 to 25 of their best yearling sheep in various national purebred sheep shows around the country, and their sheep often won awards at these shows. Mr. Hoyt and David Barnes created documents that purported to represent transactions in which RCR #1 purchased sheep from Barnes Ranches. These documents included a “livestock bill ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011