Patricia M. Mora, F.K.A. Patricia Rasberry - Page 7




                                        - 7 -                                         
          partnership losses).  It appears that most of petitioner and                
          intervenor’s 1986 refund was also paid to the Shorthorn                     
          partnership.                                                                
               Respondent examined the Shorthorn partnership’s returns, and           
          issued notices of final partnership administrative adjustment               
          (FPAA) to the Shorthorn partnership.  Walter J. Hoyt III, as tax            
          matters partner for the Shorthorn partnership, filed a petition             
          with this Court, docket No. 29295-89, which was consolidated with           
          other Hoyt partnership cases.                                               
               After the partners’ stipulations in Bales v. Commissioner,             
          supra, the tax matters partner for the Shorthorn partnership                
          stipulated most of the issues raised by the Commissioner.  The              
          Tax Court issued an opinion affirming the Commissioner’s                    
          calculations regarding the effect of the stipulation on each of             
          the partnerships, which is reported at Shorthorn Genetic                    
          Engineering 1982-2, Ltd. v. Commissioner, T.C. Memo. 1996-515.              
          On the basis of the stipulations and opinion, a substantial                 
          portion of the Shorthorn partnership losses was disallowed.                 
          According to respondent, the losses were disallowed because,                
          among other things, the Shorthorn partnership overstated both the           
          number and value of animals owned by the partnership that formed            
          the basis for the deductions.                                               
               On the basis of the stipulated and decided issues at the               
          partnership level, respondent denied a portion of the losses that           






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011