- 9 - some point before the years in issue, Jay Hoyt decided that when the Hoyt family sold breeding cattle to a cattle-breeding partnership, he should not be negotiating as general partner of that cattle-breeding partnership its purchase of those same cattle and then managing that partnership’s cattle under a sharecrop agreement between the partnership and W.J. Hoyt & Sons. However, despite these different entities the Hoyt family employed, Jay Hoyt continued to head the Hoyt organization and was ultimately in charge of all of the Hoyt organization’s operations. All of the individuals managing various entities in 5(...continued) among other things, determined with respect to the transactions of several earlier cattle partnerships (which the Hoyt family organized and operated, including DF #1) that (1) those partnerships had acquired the benefits and burdens of ownership with respect to specific breeding cattle and (2) the promissory notes they issued were valid recourse indebtedness. In addition, Jay Hoyt (as tax matters partner) and respondent later concluded settlements with respect to the years 1980 through 1986 of those partnerships and a number of other cattle-breeding partnerships the Hoyt family organized (including settlements for 1980 through 1986 for some of the seven cattle-breeding partnerships involved in the instant cases). In the instant cases, which involve the years 1987 through 1992 and concern transactions the seven cattle-breeding partnerships in issue entered into after those in Bales, however, the parties disagree whether these seven cattle- breeding partnerships obtained actual ownership of specific breeding cattle and whether the promissory notes the partnerships issued were valid indebtedness. The terms “sale”, “sold”, “purchase”, “partnership’s cattle”, and similar terms, insofar as relating to subsequent transactions now in issue, are used herein for convenience and are not intended as ultimate findings or conclusions concerning the partnerships’ acquisition of cattle. Similarly, the use herein of such terms indicating that interest or principal payments were due should not be construed as our conveying any legal conclusion concerning the validity of the partnerships’ promissory notes.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