- 4 -
Commissioner, T.C. Memo. 1989-568. The Bales case involved
deficiencies in Federal income taxes of individual limited
partners for the taxable years 1974 through 1980 who had invested
in Florin Farms #1, #2, #3, #4, and #5, Durham Farms #1, #2, #3,
and #4, and Washoe Ranches #1, #2, #3, #4, #5, and #6. As a
result of our opinion in Bales v. Commissioner, supra, on May 20,
1993, Walter J. Hoyt III, the general partner and tax matters
partner, entered into a settlement with respondent's Sacramento,
California, Appeals Office, setting forth the basis of settling
all Hoyt cattle partnership cases for the taxable years 1980
through 1986.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits received into evidence
are incorporated by this reference.
The partnerships purchased the cattle used in their breeding
operations from Hoyt & Sons Ranches (Ranches). In payment for
the cattle purchased, the partnerships executed promissory notes
payable to Ranches. During the taxable years in issue, they
transferred cattle to Ranches in payment of principal and
interest due on the notes. The parties introduced documentary
evidence as to each of these transactions: Bills of sale from
Ranches to the partnerships; promissory notes from them to
Ranches; and bills of sale from them to Ranches.
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