Washoe Ranches # 1, Ltd. Washoe Ranches #2, Ltd., Washoe Ranches #3, Ltd., Washoe Ranches #4, Ltd., Washoe Ranches #5, Ltd., Washoe Ranches #6, Ltd., Washoe Ranches #7, Ltd., Walter J. Hoyt III, - Page 2

                                        - 2 -                                         
                    22073-89,   26720-89,                                             
                    27676-89,   27722-89,                                             
                    28133-89,      6211-90,                                           
                   6262-90,  7560-90.                                                

               Walter J. Hoyt III, pro se.                                            
               Margaret Martin, for respondent.                                       

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               DAWSON, Judge:  These consolidated cases were assigned to              
          Special Trial Judge Stanley J. Goldberg pursuant to section                 
          7443A(b)(4) and Rules 180, 181, and 183.2  The Court agrees with            
          and adopts the opinion of the Special Trial Judge which is set              
          forth below.                                                                
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               GOLDBERG, Special Trial Judge:  Respondent issued a notice             
          of final partnership administrative adjustments to each limited             
          partnership involved in these consolidated cases determining                
          adjustments in the amounts and for the tax years as set forth in            
          the Appendix hereto.                                                        
               Walter J. Hoyt III (petitioner), the tax matters partner for           
          each of the limited partnerships (partnerships) involved herein,            
          filed a petition for redetermination of the partnership                     
          adjustments.  All issues, except one, have been settled by                  
          stipulation so that the only remaining issue to be decided is               

          2    Unless otherwise indicated, all section references are to the Internal 
          Revenue Code in effect for the years in issue.  All Rule references are to the
          Tax Court Rules of Practice and Procedure.                                  




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