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to generate the management fees and sales income (from
Management’s then “transferring” to Ranches large numbers of
animals “received” from the partnerships) respondent determined.
Accordingly, we hold that the 1987, 1988, 1989, and 1990 farm
income adjustments respondent determined against Management–-to
the extent of the management fee income and the sale income from
Ranches--cannot be sustained. In all other respects, the Court
sustains the 1987, 1988, 1989, and 1990 farm income adjustments
respondent determined. See Rules 142(a), 240(a).
Petitioners offered no evidence concerning the 1990 section
1231 gain adjustment respondent determined against Management
from its sale of certain other assets. Consequently, the Court
sustains respondent’s determination in the FPAA that Management
had $720,526 of section 1231 gain for the 1990 tax year. See
Rules 142(a), 240(a).
Petitioners offered no evidence concerning the 1988, 1989,
and 1990 taxable distribution adjustments respondent determined
Management had from its receipt of assets from Ranches and Hoyt &
Sons Ranch Properties. On brief, respondent acknowledges that
since it was unclear whether Management received $8,160,745 of
the assets in 1989 or 1990, the same $8,160,745 amount was
included in both 1989 and 1990. Respondent now states that he
believes the $8,160,745 amount belongs in Management’s income for
1990. Consequently, the Court sustains respondent’s
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