- 3 - Partner, docket No. 21954-90; Durham Genetic Engineering 1983-2, Ltd., Durham Genetic Engineering 1983-3, Ltd., Durham Genetic Engineering 1984-1, Ltd., Durham Genetic Engineering 1984-2, Ltd., Durham Genetic Engineering 1984-3, Ltd., Durham Genetic Engineering 1984-4, Ltd., Walter J. Hoyt III, Tax Matters Partner, docket No. 23531-90; Durham Genetic Engineering 1985-1, Ltd., Durham Genetic Engineering 1985-2, Ltd., Durham Genetic Engineering 1985-3, Ltd., Durham Genetic Engineering 1985-4, Ltd., Durham Genetic Engineering 1985-5, Ltd., Walter J. Hoyt III, Tax Matters Partner, docket No. 28577-90. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge: These consolidated cases were assigned to Special Trial Judge Stanley J. Goldberg pursuant to section 7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with and adopts the opinion of the Special Trial Judge which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE GOLDBERG, Special Trial Judge: Respondent issued a notice of final partnership administrative adjustments to each limited partnership involved in these consolidated cases, determining adjustments in the amounts and for the tax years as set forth in the Appendix. Walter J. Hoyt III (petitioner), the tax matters partner for each limited partnership (referred to collectively as partnerships) involved herein, filed a petition for redetermination of the partnership adjustments. All issues, except one, have been settled by stipulations so that the only remaining issue for decision is the proper allocation of partnership items to the partners to be calculated in accordance with a settlement agreement dated May 20, 1993, entered into between Walter J. Hoyt III, and respondent's Sacramento,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011