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 4

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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                  

          calculating the allocations is proper, then the parties agree               
          that the amounts shown on the proposed decision documents are               
               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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