River City Ranches #4 - Page 3




                                        - 3 -                                         
               After concessions, the primary issues for decision are:  (1)           
          Whether each of these three partnerships, River City Ranches #4,            
          J.V., Walter J. Hoyt III, Tax Matters Partner (RCR #4), River               
          City Ranches #6, J.V., Walter J. Hoyt III, Tax Matters Partner              
          (RCR #6), and Ovine Genetic Technology 1990, J.V., Walter J. Hoyt           
          III, Tax Matters Partner (OGT 90), purchased and acquired                   
          ownership of breeding sheep that are subject to an allowance for            
          depreciation under section 167; (2) whether each partnership has            
          substantiated and is entitled to its claimed depreciation                   
          deductions with respect to its breeding sheep for the years in              
          issue; (3) whether RCR #4 and RCR #6 are entitled to certain                
          interest deductions with respect to the promissory note each                
          partnership issued in connection with the purported acquisition             
          of its breeding sheep; (4) whether each partnership is entitled             
          to certain farm, guaranteed payment, and other deductions it                
          claimed; and (5) whether RCR #4 and RCR #6 each had certain                 
          capital gains income and/or additional farm income for some of              
          the years in issue.                                                         






               3(...continued)                                                        
          30, 1989, year ended Sept. 30, 1990, and 1991.  Respondent                  
          granted River City Ranches #6 permission to change to a taxable             
          year ended Sept. 30, 1989, beginning with its year ended Sept.              
          30, 1989.  The year in issue for Ovine Genetic Technology 1990 is           
          1991.                                                                       




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