- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011