- 71 -                                         
               The record further reflects that DF #1, during some of the             
          years in issue, also claimed interest deductions with respect to            
          certain notes it issued in connection with transactions that                
          might have been the subject of the Bales decision.  These alleged           
          interest payments were “made” by the partnership purportedly                
          transferring back (at inflated values) “cattle” to the Hoyt                 
          organization.  For instance, a Hoyt organization payment summary            
          and a payment receipt reflect that, in early 1987, DF #1                    
          transferred to the Hoyt organization 14 heifers having a stated             
          total value of $111,056 (which works out to an average stated               
          value per heifer of just under $8,000) and that the Hoyt                    
          organization credited this $111,056 “payment” against three of DF           
          #1's promissory notes, including two notes that DF #1 issued,               
          respectively, in 1976 and 1977.  The payment summary further                
          reflects that the Hoyt organization credited this $111,056                  
          “payment” against the three notes, allocating $13,231 to interest           
          and $97,925 to principal.                                                   
               We are aware that the DF #1 notes issued in connection with            
          the transactions involved in Bales were previously determined by            
          this Court to be valid recourse indebtedness.  However, in the              
          instant cases, the Court does not believe DF #1 to be entitled to           
          interest deductions on those notes for the years in issue.  As              
          indicated previously, petitioner’s collateral estoppel claim is             
          not properly before the Court.  See supra note 39.  Moreover, by            
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