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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 from
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