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and 1982 taxable years. Petitioners subsequently became limited
partners in both the Durham Shorthorn Breed Syndicate 1987-E
partnership (DSBS 87-E) and the Timeshare Breeding Service Joint
Venture partnership (TBS J.V.). These three partnerships,
hereinafter collectively referred to as the Hoyt partnerships,
are TEFRA1 partnerships subject to the provisions of sections
6221 through 6233 for all post-1982 taxable years in issue.
Petitioners claimed losses from the Hoyt partnerships through
1992.
Walter J. Hoyt III (Mr. Hoyt) was designated the tax matters
partner (TMP) on the Hoyt partnership returns for the years in
issue, with the sole exception of SGE 83-2, which did not list a
designated TMP on its partnership return for the 1983 tax year.2
As TMP, Mr. Hoyt executed extensions of the periods of
limitations, extending the periods for assessment and collection
for the Hoyt partnerships as set forth below:
1 Congress enacted the TEFRA partnership procedures as part of
the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA),
Pub. L. 97-248, sec. 402(a), 96 Stat. 324, 648.
2 Though Mr. Hoyt was not designated TMP on SGE 83-2's 1983
return, he signed the 1983 tax return for SGE 83-2 as general
partner. Mr. Hoyt also executed an extension of the period of
limitations for SGE 83-2's 1983 tax year on Sept. 26, 1986.
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