Hoyt and Sons Ranch Properties, Ltd., A Nevada Limited Partnership, Walter J. Hoyt, III, Tax Matters Partner - Page 2

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          Procedure.)  The Court agrees with and adopts the Opinion of the            
          Special Trial Judge, which is set forth below.                              
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               ARMEN, Special Trial Judge:  This case is before the Court             
          on respondent's Motion to Dismiss for Lack of Jurisdiction.  The            
          issue to be decided is whether the petition for readjustment was            
          filed within the period prescribed in section 6226.                         
          Background                                                                  
               On May 17, 1995, Hoyt and Sons Ranch Properties, Ltd. (the             
          partnership) filed a bankruptcy petition with the U.S. Bankruptcy           
          Court for the District of Oregon.                                           
               On July 17, 1996, respondent issued a notice of final                  
          partnership administrative adjustment (FPAA) to Walter J. Hoyt,             
          III (Mr. Hoyt or petitioner), the partnership's tax matters                 
          partner (TMP), determining adjustments to the partnership's                 
          return (Form 1065) for the taxable year 1992.  On April 2, 1997,            
          respondent issued an FPAA to Mr. Hoyt, determining adjustments to           
          the partnership's return (Form 1065) for the taxable year 1993.             
          In addition to serving as the partnership's TMP, Mr. Hoyt is a              
          notice partner of the partnership within the meaning of section             
          6231(a)(8).                                                                 
               On June 18, 1997, the bankruptcy court issued an order                 
          granting Mr. Hoyt's motion for an order to release the so-called            
          bankruptcy automatic stay (imposed under 11 U.S.C. sec. 362(a)(8)           






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