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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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