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they are entered only and are not binding for any other purpose.
Rule 91(e). Therefore, the stipulations from the other cases are
not evidence in these cases.
Petitioner has offered no other evidence to show that any
cash was paid to Ranches. The only evidence introduced by
petitioner is the bills of sale detailing the number of cattle
transferred as payment on the notes. Moreover, petitioner
stipulated that the payments at issue were made by transferring
cattle, not cash. This stipulation is not clearly contrary to
the facts disclosed on the record. Therefore, we find that the
partnerships made interest and principal payments beginning in
the sixth year of the notes payable by transferring cattle. The
partnerships must recognize ordinary income on the transfer of
cattle in the amounts stipulated.
Allocations of Partnership Items
When a petition for readjustment of partnership items has
been filed properly, this Court has jurisdiction to decide all of
the partnership items of the partnership and the proper
allocation of these items to the partners for the partnership
taxable year at issue. Sec. 6226(f). Partnership items are
those items required to be taken into account for the
partnership's taxable year under subtitle A which are to the
extent provided by the regulations "more appropriately determined
at the partnership level than at the partner level." Sec.
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