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Accordingly, we hold that the 1988 through 1992 tax year capital
gains and/or other farm income adjustments respondent determined
against these foregoing partnerships cannot be sustained.
Issue 9. Management’s Deductions and Credits
In the FPAA’s issued to Management for its 1987, 1988, 1989,
and 1990 tax years, respondent disallowed various deductions and
credits claimed by Management.
Among the adjustments in issue between the parties are tens
of millions of dollars of other farm deductions attributable to
large numbers of cattle Management purportedly had received from
numerous cattle-breeding partnerships and then ostensibly
transferred to Ranches in payment of feed, management,
consulting, freight services, and other goods and services
Ranches provided to Management. As discussed supra in connection
with Issue 1, the Court has determined certain specified cattle-
breeding partnerships, during 1987 through 1990, did not acquire
the benefits and burdens of ownership with respect to the
breeding cattle they purportedly acquired from the Hoyt
organization. As they and other cattle-breeding partnerships the
Hoyt organization formed and operated from 1987 through 1990,
were never the owners for tax purposes of any breeding cattle,
the Court concludes that Management “received” no cattle from
these partnerships to “transfer” to Ranches in “payment” of these
alleged goods and services Ranches provided to Management.
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