Hoyt and Sons Ranch Properties, Ltd., A Nevada Limited Partnership, Walter J. Hoyt, III, Tax Matters Partner - Page 4

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          the petition was filed by petitioner, who is also a notice                  
          partner, within the 60-day period prescribed in section                     
          6226(b)(1).  See Barbados #6 Ltd. v. Commissioner, 85 T.C. 900,             
          904 (1985).  (Consistent with this concession, we shall deny                
          respondent's Motion to Dismiss for Lack of Jurisdiction insofar             
          as the taxable year 1993 is concerned.)                                     
               On November 5, 1997, the Court issued an order calendaring             
          respondent's motion to dismiss for hearing on December 3, 1997.             
          The order included a reminder to the parties of the applicability           
          of Rule 50(c).  On November 19, 1997, petitioner filed a motion             
          to continue the hearing.  On November 21, 1997, the Court granted           
          petitioner's motion and continued the hearing of this matter to             
          December 17, 1997.  The Court again reminded the parties of the             
          applicability of Rule 50(c).  On December 5, 1997, petitioner               
          filed a second motion to continue the hearing.  Petitioner's                
          motion was denied on December 10, 1997.                                     
               This matter was called for hearing at the Court's motions              
          session in Washington, D.C., on December 17, 1997.  Counsel for             
          respondent appeared at the hearing and presented argument in                
          support of respondent's motion to dismiss the taxable year 1992.            
          No appearance was made by or on behalf of petitioner, nor did               
          petitioner file a statement with the Court pursuant to Rule                 
          50(c).                                                                      








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