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additions to tax under sections 6653(a)(1) and 6659 in the
respective amounts of $414.40 and $2,457.30, and under section
6653(a)(2) in the amount of 50 percent of the interest due on the
underpayment of tax attributable to negligence or intentional
disregard of rules and regulations. Respondent also determined
that interest due on the deficiency for 1982 would be computed
pursuant to the increased interest rate imposed under section
6621(c). For the reasons discussed below, we grant respondent's
motions.
Background
The income tax adjustments at issue relate to the
disallowance of the investment tax credit and of a partnership
loss claimed with respect to petitioners' investment in Florin
Farms #6. This case is part of a larger group of cases
designated as the Hoyt Farms group, named after the organizer and
operator of numerous cattle and sheep breeding partnerships, W.J.
Hoyt Sons, and/or Walter J. Hoyt III.
At the time of the filing of their petition, petitioners
were pro se. However, on November 13, 1987, an entry of
appearance was filed on their behalf by Messrs. Jim B. Dismukes
and Joel Drum. This case was set for a pretrial hearing in San
Francisco, California, on May 26, 1993, for the purpose of
determining whether the case would be tried, and, if so, the most
expeditious manner to proceed in light of the case of Bales v.
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