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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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