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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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