- 3 - each limited partnership's correct amount of Schedule F income, if any, to be calculated in accordance with a settlement agreement (the agreement) dated May 20, 1993, entered into between Walter J. Hoyt III, and respondent's Sacramento, California, Appeals Office. At trial, respondent submitted a motion for entry of decision and a proposed decision document in each case that includes the Schedule F income. Petitioner objected to respondent's motion as stated. On the record respondent recharacterized her motion as a motion for summary judgment that was filed as such. If we decide that the agreement provides for the inclusion of Schedule F income, then the parties agree that the amount of Schedule F income reflected in each proposed decision document is correct, and that we may enter the proposed decision document in each case. However, if we decide that the agreement does not provide for Schedule F income, then we may enter a decision in each case minus the Schedule F income shown thereon. These consolidated cases involved adjustments to partnership income of Washoe Ranches #1 through #7, Florin Farms #1 through #7, and Durham Farms #1 through #6 for taxable years ended December 31, 1983, 1984, 1985, and 1986. All the partnerships are limited partnerships formed to engage in the business of cattle breeding. This Court has previously considered the tax consequences of the Hoyt family cattle breeding operations in Bales v.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011