- 28 - Petitioner also makes the following secondary arguments: (1) Various partners' interests have been terminated due to the partners' actions or inactions; (2) a large number of partners defaulted on the notes to Ranches in 1987, and their cattle have been repossessed; therefore, these partners should not be allocated any partnership debt; and (3) certain partners terminated their interests in 1994 by letters alleging that the partnerships were terminated shortly after inception. Respondent objected to any evidence of these purported actions or inactions as irrelevant because they were subsequent to the taxable years at issue. Evidence is relevant if it tends to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence. Fed. R. Evid. 401. Petitioner proffered evidence of various livestock exhibitions, sales and programs, letter writing campaigns from 1992 through 1994, and a management agreement between Shorthorn Genetic Engineering 1983 #3 and W.J. Hoyt Sons Management Co., Ltd., for years beginning with 1993, as well as termination of interest letters from partners written in 1994. Petitioner has provided no explanation of the relevance of these documents to the taxable years at issue. The evidence does not tend to show that any partners withdrew from or had their interests in any of the partnerships terminated during thePage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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