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Petitioners claim that no money needed to change hands between
Kildare Timmy and Mr. Ramsburg because the money that Mr.
Ramsburg allegedly paid to Kildare Timmy to purchase the horses
and the stud rights in question would have been immediately
distributed by Kildare Timmy to Mr. Ramsburg in liquidation of
his interest in that partnership. On the record before us, we
reject petitioners’ self-serving claim. Petitioners, in effect,
ask us to accept their contention that Mr. Ramsburg purchased
Kildare Timmy’s racing and breeding horses and stud rights
because that is what Mr. Ramsburg told (1) Mr. Stottlemeyer, his
longtime friend and partner, (2) Mr. Rippeon, his accountant who
prepared Kildare Timmy’s 1998 partnership return and petitioners’
1998 return, and (3) the Court at the trial in this case. As
stated above, we are unwilling to rely on the testimony of Mr.
Ramsburg, Mr. Stottlemeyer, and Mr. Rippeon to establish peti-
tioners’ position in this case. We also are unwilling to rely on
documents in the record that were prepared, and/or that contained
information supplied, by Mr. Ramsburg and/or Mr. Stottlemeyer,
such as Kildare Timmy’s 1998 partnership return in which that
partnership claimed to have sold to Mr. Ramsburg its racing and
breeding horses and stud rights for their respective book values.
Based upon our examination of the entire record before us,
25(...continued)
Ramsburg in liquidation of his interest in that partnership was
the Kildare Timmy bank account balance.
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