- 31 - 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.Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
Last modified: May 25, 2011