- 4 - Sacramento, California, Appeals Office, setting forth the basis of settling all Hoyt cattle partnership cases for the taxable years 1980 through 1986. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the exhibits received into evidence are incorporated by this reference. The parties have agreed that the testimony and transcripts of the proceedings in the cases at docket No. 8916-89, Washoe Ranches #1, Ltd., et al., and related cases, and docket No. 22003-89, Shorthorn Genetic Engineering 1982-1, Ltd., et al., and related cases, will be incorporated by this reference into the record in these cases. The partnerships purchased the cattle used in their breeding operations from Hoyt & Sons Ranches (Ranches). In payment for the cattle purchased, the partnerships executed promissory notes payable to Ranches. Thereafter, the partners signed assumption of liability agreements, thereby assuming personal liability for these recourse partnership liabilities. Principal payments on the notes became due starting in the sixth year after the notes were signed. During the taxable years in issue, the partnerships transferred cattle to Ranches in payment of principal and interest due on the notes. The parties introduced documentary evidence of each of these transactions: bills of sale fromPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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