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 18

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          of various livestock exhibitions, sales, and programs, letter               
          writing campaigns from 1992 through 1994, and a management                  
          agreement between Shorthorn Genetic Engineering 1983 #3 and W.J.            
          Hoyt Sons Management Co., Ltd., for years beginning with 1993, as           
          well as termination of interest letters from partners written in            
          1994.  Petitioner has provided no explanation of the relevance of           
          these documents to the taxable years at issue.  The evidence does           
          not tend to show that any partners withdrew from or had their               
          interests in any of the partnerships terminated during the                  
          taxable years at issue.  Respondent's objection is sustained.               
               The only evidence in the record that any cattle were                   
          repossessed is petitioner's own general testimony that cattle               
          were repossessed.  Even if we believed that the cattle were                 
          repossessed by Ranches, the repossession occurred after the                 
          taxable years at issue, and is not relevant to these cases.                 
               To reflect the foregoing,                                              

                                        An appropriate order and decision             
                                   will be entered in each case.                      

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