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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 were
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