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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
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