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MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge: These consolidated cases were assigned to
Special Trial Judge Stanley J. Goldberg pursuant to section
7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with
and adopts the opinion of the Special Trial Judge which is set
forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
GOLDBERG, Special Trial Judge: Respondent issued a notice
of final partnership administrative adjustments to each limited
partnership involved in these consolidated cases, determining
adjustments in the amounts and for the tax years set forth in the
Appendix.
Walter, J. Hoyt III (petitioner), the tax matters partner
for each limited partnership (partnerships) involved herein,
filed a petition for redetermination of the partnership
adjustments. Most issues have been settled by stipulations so
that the only remaining issues to be decided are: (1) Each
limited partnership's correct amount of Schedule F income, if
any, and (2) the proper allocation of partnership items to the
partners. At trial, respondent filed a "Motion for Entry of
2 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
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Last modified: May 25, 2011