- 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 the
Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 NextLast modified: May 25, 2011