Jacob R. Ramsburg, Jr. and Norma J. Ramsburg - Page 31

                                        - 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