Shorthorn Genetic Engineering 1982-2, Ltd., Shorthorn Genetic Engineering 1982-4, Ltd., Shorthorn Genetic Engineering 1982-5, Ltd., Walter J. Hoyt III, Tax Matters Partner, et al. - Page 3

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          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,                    

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