Richard K. and Marilyn J. Phillips - Page 6




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               Pursuant to the stipulations of the parties,3 the periods of           
          limitations for the following years are still in issue:  (1) The            
          1983, 1987, 1988, and 1989 taxable years for SGE 83-2; (2) the              
          1988 and 1989 taxable years for DSBS 87-E; and (3) the 1988,                
          1989, and 1990 taxable years for TBS J.V.                                   
               On April 23, 1984, the Examination Division of the Internal            
          Revenue Service (Examination Division) requested that the                   
          Criminal Investigation Division (CID) of the Internal Revenue               
          Service (IRS) investigate Mr. Hoyt for allegedly preparing false            
          and fraudulent individual income tax returns for 12 individuals.4           
          Mr. Hoyt allegedly advised the 12 individuals that although they            
          did not join certain Hoyt-managed partnerships until 1984, they             
          could deduct partnership losses on their 1983 Federal income tax            
          returns.                                                                    

          3    The parties have stipulated that the periods of limitations            
          for the assessment and collection of any deficiency in income tax           
          due from petitioners with respect to:  (1) Shorthorn Genetic                
          Engineering 83-2 partnership for the 1984, 1985, and 1986                   
          calendar years and for its fiscal years ending Sept. 30, 1990 and           
          1991; and (2) Durham Shorthorn Breed Syndicate 87-E partnership             
          for the fiscal years ending Sept. 30, 1990 and 1991, have not               
          expired.                                                                    
               Petitioners concede that the statute of limitations does not           
          bar assessment and collection of any income tax deficiency from             
          the Timeshare Breeding Service Joint Venture partnership for its            
          1991 calendar year or any partnership in this case whose taxable            
          year ended with, or within, petitioners' 1992 calendar year.                
          Partnership items of each of those partnerships for those years             
          became nonpartnership items as of Apr. 17, 1995.                            
          4    None of the 12 individuals are petitioners in the present              
          case.                                                                       






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