- 11 - Under the agreements, the partnerships were to purchase the sheep by issuing promissory notes to Barnes Ranches. The notes were then personally assumed by the partners of the partnership under an assumption agreement signed by Hoyt. The promissory notes that the sheep partnerships issued for the purchase of the sheep did not represent bona fide recourse debt. The security interests granted to Barnes Ranches by the partnerships to secure payment on the partnership promissory notes were not valid. Barnes Ranches never requested payment from the partnerships or the individual partners on the promissory notes, and the partnerships were not obligated to pay their promissory notes. The individual partners of the partnerships were not personally liable for the promissory notes to Barnes Ranches and never directly paid Barnes Ranches on the notes. The assumption agreements that Hoyt signed on behalf of individual partners with respect to the partnerships’ promissory notes were not legally enforceable against the individual partners. Consequently, the promissory notes were not bona fide recourse debt, were not valid indebtedness, and were illusory, having no practical economic effect. The purchase price of the flock purportedly sold to each partnership exceeded the value of each partnership’s flock, and many of the sheep purportedly sold did not exist. The bills of sale that Barnes Ranches issued the sheep partnerships listedPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 NextLast modified: November 10, 2007