- 3 -
Additions to Tax Additional
Year DeficiencySec. Sec. Sec. Sec. Sec. Interest
6651(a) 6653(a) 6653(a)(1)(B) 6659 6661 Sec. 6621(c)
1980 $3,917 –– –- –- –--- 1
1981 17 –- -– –- -– -- --
1982 1,248 -– -– –- –- -– 1
1983 11,334 $1,043 -– –-–- –- 1
1984 1,196 –- -– –- -– –- 1
–--– –-
1985 4,662 –- -– –- 1
1986 8,068 139 -– –- -– –- 1
7,402 $2,760 2 1
1987 54,708 $16,412 $13,677
1
1988 52,048 8,981 2,670 -15,614 13,012
Penalties
Sec. Sec. Sec. Sec.
6662(h) 6662(e) 6662(d) 6662(c)
1989 $43,986 $4,008 $17,594 $8,797 $8,797 $8,797
1990 25,515 4,697 6,593 3,296 5,103 5,103
1991 41,240 7,435 16,238 8,119 8,248 8,248
1992 222,282 10,792 88,913 44,456 44,456 44,456
1
Respondent determined that interest is to be computed at 120 percent of the interest
payable under sec. 6601 with respect to any substantial underpayment attributable to tax-
motivated transactions.
2 Respondent determined that an additional amount is to be computed equal to 50 percent of
the interest attributable to the entire 1987 underpayment pursuant to sec. 6653(a)(1)(B).
After concessions, the sole issue to be decided is whether
the periods of limitations for the years in issue expired before
the issuance of the final partnership administrative adjustments
(FPAA's). The resolution of this issue depends upon whether
Walter J. Hoyt III, as tax matters partner for the partnerships
involved herein, validly executed various Forms 872, Consent to
Extend the Time to Assess Tax.
This case was submitted fully stipulated pursuant to Rule
122. The stipulations of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioners lived in Shell Beach, California.
In 1983, petitioners became limited partners in the
Shorthorn Genetic Engineering 1983-2 partnership (SGE 83-2) and
claimed losses and investment tax carrybacks to the 1980, 1981,
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