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that a limited partner may be expelled for defaulting on
partnership obligations, much less that an expulsion would be
retroactive to the beginning of the partnership.
Moreover, the settlement agreement expressly provides for
the inclusion of partners who default on their note obligations
to Ranches (inactive partners) in the original allocations of the
partnership debt. The agreement is binding on the parties. Sec.
6224.
Petitioner also makes the following secondary arguments:
(1) Various partners, by their actions or inactions, failed to
abide by the provisions of the amended partnership agreement;
therefore their interests have been terminated; (2) a large
number of partners defaulted on the notes to Ranches in 1987, and
their cattle have been repossessed; therefore these partners
should not be allocated any partnership debt; and (3) certain
partners terminated their interests in 1994 by letters alleging
that the partnerships were terminated shortly after inception.
Respondent objected to any evidence of these purported
actions or inactions as irrelevant because they were subsequent
to the taxable years at issue.
Evidence is relevant if it tends to make the existence of
any fact that is of consequence to the determination of the
action more probable or less probable than it would be without
the evidence. Fed. R. Evid. 401. Petitioner proffered evidence
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