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section 167 for the years in issue; (2) whether those seven
cattle-breeding partnerships each have substantiated and are
entitled to their claimed depreciation deductions with respect to
their breeding cattle for the years in issue; (3) whether those
seven cattle-breeding partnerships are entitled to certain
interest deductions with respect to the promissory note each
partnership issued in connection with the purported acquisition
of its breeding cattle; (4) whether any of those seven cattle-
breeding partnerships is entitled to farm, guaranteed payment,
and certain other deductions it claimed; (5) whether DGE 84-3 and
SGE 84-5 are entitled to an investment credit for 1987; (6)
whether some of those seven cattle-breeding partnerships had
certain additional farm income for some of the years in issue;
(7) whether the eighth partnership, W.J. Hoyt Sons Management
Co., Gary L. Blackburn, Tax Matters Partner (Management), is
entitled to certain credits and deductions it claimed for the
years in issue; and (8) whether Management had certain additional
farm and other income for the years in issue.
FINDINGS OF FACT
Some of the facts and certain documents have been stipulated
for trial pursuant to Rule 91 and are found accordingly. The
Court incorporates the parties’ stipulations in this opinion by
reference.
At the times their respective petitions herein were filed,
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