Hoyt and Sons Ranch Properties, Ltd., A Nevada Limited Partnership, Walter J. Hoyt, III, Tax Matters Partner - Page 3

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          (1988)) to permit the filing of a petition for readjustment with            
          this Court.  The order states in pertinent part as follows:                 
                    The Court considered the Motion for Order for                     
               Release of Stay to File Tax Court Petition filed by                    
               Walter J. Hoyt III in connection with the Motion to                    
               Limit Trustee's Duties or, in the alternative, for                     
               Instructions Regarding IRS Notice.                                     
                    Based upon the record herein and the Court being                  
               otherwise duly advised, it is, to the extent an order                  
               is necessary, the Motion for an Order to Release of                    
               Stay to File Tax Court Petition [sic], filed by Walter                 
               J. Hoyt III, be and hereby is granted.                                 
          On July 21, 1997, petitioner filed a petition for                           
          readjustment with the Court contesting the FPAA's described                 
          above.  At the time that the petition was filed, the partnership            
          maintained its principal place of business at Burns, Oregon.                
               Respondent subsequently filed a Motion to Dismiss for Lack             
          of Jurisdiction on the ground that the petition for readjustment            
          was not timely filed.  Petitioner filed an objection to                     
          respondent's motion asserting that the petition for readjustment            
          was timely filed within the period prescribed in section 6213(f)            
          following the issuance of the bankruptcy court's order lifting              
          the automatic stay.  In response to petitioner's objection,                 
          respondent maintains that the petition is untimely with respect             
          to the FPAA for 1992, despite the partnership's bankruptcy case,            
          on the ground that the automatic stay did not serve as a bar to             
          filing of a petition for readjustment for that year.  On the                
          other hand, respondent now concedes that the petition for                   
          readjustment is timely with respect to the FPAA for 1993 because            




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