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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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