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Rules 142(a), 240(a).
On brief, petitioners concede they have failed to produce
any evidence regarding the section 179 expense that Management
claimed for its 1989 tax year. Consequently, we sustain
respondent’s determination in the FPAA disallowing Management
such expense for the 1989 tax year. See Rules 142(a), 240(a).
Issue 10. Management’s Income
In the FPAA’s issued to Management for its 1987, 1988, 1989,
and 1990 tax years, respondent determined that Management (1) had
(a) substantial management fees from its receipt of calves and
culls from numerous cattle-breeding partnerships and (b)
substantial sale income from its transfer of much of those same
cattle to Ranches, (2) had unreported 1990 capital gains income
from its sale of certain other assets, (3) received taxable
distributions of assets from Ranches and Hoyt & Sons Ranch
Properties, and (4) had income from the discharge of
indebtedness.
As discussed supra in connection with Issues 1, 8, and 9,
the Court has determined that cattle-breeding partnerships the
Hoyt organization formed and operated from 1987 through 1992 did
not acquire the benefits and burdens of ownership with respect to
breeding cattle they purportedly acquired from the Hoyt
organization and were not the owners for tax purposes of any
breeding cattle. These partnerships thus did not have any cattle
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