Poison Creek Ranches #1, Ltd., Poison Creek Ranches #2, Ltd., Poison Creek Ranches #3, Ltd., Poison Creek Ranches #4, Ltd., Walter J. Hoyt, III, Tax Matters Partner, et al. - Page 4

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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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