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 3

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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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