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information listed above and was for the purpose of authorizing
the disclosure of taxpayer information concerning certain of the
Hoyt Farms partnerships, not including Ranch Properties. Nowhere
in the Cobb letter, the authorization, or its Exhibits 1 and 2,
does a group of partners having in the aggregate a 5-percent or
greater interest in Ranch Properties for tax year 1994 request
recognition as a notice group or designate one of its members to
receive notices on behalf of such group. See sec. 301.6223(b)-
1T, Temporary Proced. & Admin. Regs., supra. To the contrary,
Exhibit 1 states that Mr. Hoyt had no “authority for
authorization” as to “the two Hoyt and Sons Ranch Properties
partnerships”. To apply such a broad and loose interpretation to
these documents, as SGE would have the Court do, would render the
specific sections of the Code and regulations useless.
Accordingly, because SGE failed to meet any of the requirements
to request treatment as a notice group, or as a member or
designee of such a group, it is not treated under section
6223(e)(1)(B) as entitled to the notice specified in section
6223(a).
According to the Schedule K-1 issued in connection with
Ranch Properties’ 1994 partnership return, SGE was a 0.65-percent
profit, loss, and ownership holder of Ranch Properties. SGE does
not dispute that its stated interest in Ranch Properties is less
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Last modified: May 25, 2011