- 3 -
95, 20843-95, 20868-95, 21629-95, 24241-95, and 24643-95.
Walter J. Hoyt III, pro se in docket Nos. 10053-95, 11217-
95, and 12500-95.2
Walter J. Hoyt III (participant), pro se in docket Nos.
20843-95, 20868-95, 24241-95, and 24643-95.3
Gerald W. Douglas, Ann M. Murphy, Wesley F. McNamara, Paul
Robeck, Kathy I. Shaw, Catherine Caballero, and Ralph W. Jones,
for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge: These cases were assigned to Special Trial
Judge Stanley J. Goldberg, pursuant to Rules 180, 181, and 183.
All Rule references are to the Tax Court Rules of Practice and
Procedure. Section references are to the Internal Revenue Code
in effect for the years in issue. The Court agrees with and
adopts the opinion of the Special Trial Judge, which is set forth
below.
OPINION OF THE SPECIAL TRIAL JUDGE
GOLDBERG, Special Trial Judge: Respondent issued a notice
of final partnership administrative adjustment (FPAA) to each
partnership involved in these consolidated cases determining the
adjustments in the amounts and for the taxable years as set forth
2After the trial was held and the parties filed their
posttrial briefs, Walter J. Hoyt III was allowed by the Court to
withdraw as tax matters partner from these cases.
3See supra note 2.
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