- 4 -
in appendix A hereto.4
After concessions, the primary issues for decision are: (1)
Whether each of seven of the eight partnerships in the instant
cases--Durham Farms #1, J.V., Gary L. Blackburn, Tax Matters
Partner (DF #1), Shorthorn Genetic Engineering 1982-1, J.V., Gary
L. Blackburn, Tax Matters Partner (SGE 82-1), Durham Genetic
Engineering 1984-3, J.V., Gary L. Blackburn, Tax Matters Partner
(DGE 84-3), Shorthorn Genetic Engineering 1984-5, J.V., Gary L.
Blackburn, Tax Matters Partner (SGE 84-5), Durham Genetic
Engineering 1986-2, J.V., Gary L. Blackburn, Tax Matters Partner
(DGE 86-2), Timeshares Breeding Services 1989-1, J.V., Gary L.
Blackburn, Tax Matters Partner (TBS 89-1), and Timeshares
Breeding Services 1990-1, J.V., Gary L. Blackburn, Tax Matters
Partner (TBS 90-1)--purchased and acquired ownership of breeding
cattle that are subject to an allowance for depreciation under
4The years in issue for Durham Farms #1 are 1987, 1988, and
its years ended Sept. 30, 1989 through 1992. The years in issue
for Shorthorn Genetic Engineering 1982-1 are its years ended
Sept. 30, 1990 through 1992. The years in issue for Shorthorn
Genetic Engineering 1984-5 are 1987, 1988, and its years ended
Sept. 30, 1989 through 1992. The years in issue for Durham
Genetic Engineering 1984-3 are 1987, 1988, and its years ended
Sept. 30, 1989 through 1992. The year in issue for Durham
Genetic Engineering 1986-2 is 1991. The years in issue for
Timeshares Breeding Services 1989-1 are 1989 and 1991. The year
in issue for Timeshares Breeding Services 1990-1 is 1992. The
years in issue for W.J. Hoyt Sons Management Co. are its years
ended Sept. 30, 1987 through 1990. Respondent granted DF #1, SGE
82-1, SGE 84-5, and DGE 84-3, each permission to change to a
taxable year ended Sept. 30, beginning with that partnership’s
year ended Sept. 30, 1989.
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