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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.
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