Hoyt and Sons Ranch Properties Ltd. NV - Page 3




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          (Burns address).  In prior tax years of Ranch Properties, not at            
          issue before us, some of the partners of Ranch Properties,                  
          including Shorthorn Genetic Engineering 1984-5 (SGE), J.V.,                 
          received FPAA notices from respondent.  However, no other FPAA              
          notices were issued or mailed to any partner of Ranch Properties            
          other than the tax matters partner (TMP) for tax year 1994.                 
               The 90-day period within which the TMP could file a petition           
          for redetermination of partnership adjustments with this Court              
          expired on November 11, 1998.  Sec. 6226(a).  The subsequent 60-            
          day period within which a partner other than the TMP could file a           
          petition for redetermination of partnership adjustments expired             
          on January 11, 1999.  Sec. 6226(b).  SGE is a partnership and               
          pass-through-partner of Ranch Properties.  SGE, through its                 
          attorney, Montgomery Cobb (Mr. Cobb), filed a petition for                  
          readjustment of partnership items as a partner other than the TMP           
          on December 7, 2000.  According to the Schedule K-1, Partner’s              
          Share of Income, Credits, Deductions, Etc., attached to the 1994            
          partnership return, SGE was a 0.65-percent profit, loss, and                
          ownership holder of Ranch Properties.  In the FPAA notice                   
          respondent determined that the distributive share and allocation            
          for each of the 116 partners of Ranch Properties was 0.862                  
          percent.                                                                    
               The 1994 U.S. Partnership Return of Income (1994 return),              
          Form 1065, on which this case is based, was prepared by Walter J.           





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