- 4 - California, Appeals Office. At trial, respondent submitted a proposed decision document in each case and moved for summary judgment. If we find that respondent's method for 2 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. calculating the allocations is proper, then the parties agree that the amounts shown on the proposed decision documents are correct. This Court had previously considered the tax consequences of the Hoyt family cattle breeding operations in Bales v. Commissioner, T.C. Memo. 1989-568. As a result of our opinion in Bales v. Commissioner, supra, on May 20, 1993, Walter J. Hoyt III, the general partner and tax matters partner, entered into the settlement with respondent's Sacramento, California, Appeals Office, setting forth the basis for settling all Hoyt cattle partnership cases for the taxable years 1980 through 1986. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the exhibits received into evidence are incorporated by this reference. All the partnerships are limited partnerships formed to engage in the business of cattle breeding. The partnerships werePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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