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 9

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               capital account, only upon complete liquidation of all                 
               Partnership assets, less any amount of future unpaid                   
               The partnership agreement was amended in February 1987.                
          Under the amended agreement, Shorthorn Genetic Engineering 1984-5           
          was reformed as Shorthorn Genetic Engineering 1984-5, J.V., and             
          the partnership was to operate as a general partnership under the           
          laws of the State of Nevada.                                                
               Given the disposition of the issue on the merits discussed             
          below, we do not find it necessary to address respondent's                  
          motions for summary judgment, and they will be denied.                      
               When a petition for readjustment of partnership items has              
          been filed properly, this Court has jurisdiction to decide all of           
          the partnership items of the partnership and the proper                     
          allocation of these items to the partners for the partnership               
          taxable year at issue.  Sec. 6226(f).  Partnership items are                
          those items required to be taken into account for the                       
          partnership's taxable year under subtitle A which are to the                
          extent provided by the regulations "more appropriately determined           
          at the partnership level than at the partner level."  Sec.                  
          6231(a)(3).  The regulations provide that such items include:               
                    (1) The partnership aggregate and each partner's share            
               of each of the following:                                              
                    (i) Items of income, gain, loss, deduction, or credit             
               of the partnership;                                                    
                         *    *    *    *    *    *    *                              

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