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Decisions" and a proposed decision document in each case.
Respondent's motion was recharacterized as a motion for summary
judgment and filed as such. If we decide that the partnerships
recognized Schedule F income, then the parties agree the amounts
of Schedule F income reflected in the proposed decision documents
are correct. Further, if we find that respondent's method for
calculating the allocations is proper, then the parties agree
that the allocations shown on the proposed decision documents are
correct.
These consolidated cases involved adjustments to partnership
income of Poison Creek Ranches #1 through #4 for taxable years
ended December 31, 1983, 1984, 1985, and 1986. All the
partnerships are limited partnerships formed to engage in the
business of cattle breeding
The Court has previously considered the tax consequences of
the Hoyt family cattle breeding operations in Bales v.
Commissioner, T.C. Memo. 1989-568. The Bales case involved
deficiencies in Federal income taxes of individual limited
partners for the taxable years 1974 through 1980, who had
invested in Florin Farms #1, #2, #3, #4, and #5, Durham Farms #1,
#2, #3, and #4, and Washoe Ranches #1, #2, #3, #4, #5, and #6.
As a result of our opinion in Bales on May 20, 1993, Walter J.
Hoyt III, the general partner and tax matter partner, entered
into a settlement agreement (the agreement) with respondent's
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