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 7

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          interests in the partnerships have been stipulated and have been            
          received into evidence.  For the first year, respondent allocated           
          a portion of the partnership debt, which consisted of the reduced           
          amount of the notes to Ranches, to each of the partners who                 
          assumed personal liability.  The allocation was based on the                
          original percentages of partnership liabilities assumed as                  
          reflected in the partnership books and records.  The resulting              
          amounts represented each partner's beginning capital account                
          balance.  Each year respondent adjusted these balances for actual           
          capital contributions made to the partnership and increases and             
          decreases in liabilities assumed.  These adjusted balances were             
          used to determine the proportionate share of partnership items to           
          be allocated to each partner.  The capital account balances were            
          then adjusted to reflect the partnership items so allocated and             
          these balances were carried over to the next year.                          
               All of the partners included in respondent's proposed                  
          decision documents had personally assumed partnership liabilities           
          as reflected in the partnership books and records and on the                
          Federal income tax returns filed by the partnerships throughout             
          the taxable years at issue.  Furthermore, petitioner agrees that            
          respondent's calculations are consistent with the books and                 
          records of the partnerships.                                                
               Several documents relating to one of the partnerships,                 
          Shorthorn Genetic Engineering 1984-5, have also been stipulated             

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