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89-1 depreciated each breeding herd over 5 years.
TBS 90-1's return for 1992 reflects that it originally
claimed a $2,174,204 depreciation deduction on a “bull breeding”.
F. Respondent’s Examinations of the Returns of Many Cattle-
Breeding Partnerships and Certain Entities in the Hoyt
Organization; the FPAA’s Issued in the Instant Cases; and
Petitioners’ Respective Petitions
Respondent commenced examinations of returns for the years
1987 through 1992 that had been filed by (1) numerous cattle-
breeding partnerships the Hoyt organization had formed (including
DF #1, SGE 82-1, DGE 84-3, SGE 84-5, DGE 86-2, TBS 89-1, and TBS
90-1) and (2) certain Hoyt organization entities (including
Management). During these examinations, respondent asked the
cattle-breeding partnerships and their representatives, among
other things, to substantiate the depreciation and other
deductions claimed on those partnerships’ returns.
During the examinations conducted, respondent noted a number
of inconsistencies between the deductions claimed on the cattle-
breeding partnerships’ returns and various documents the
partnerships and their representatives provided. In addition,
respondent received bills of sale for some 26 newly formed
partnerships (where the 1987 return for each partnership was the
first return that partnership had filed) that reflected those
partnerships to have collectively purchased over 13,000 breeding
cattle during 1987. Only the bills of sale for 21 of the 26
newly formed partnerships had a Schedule A listing and
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