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By May 1993, the TMPs of many of the Hoyt partnerships had
filed Tax Court petitions. On May 20, 1993, respondent and Jay
Hoyt, acting as TMP, entered into a memorandum of understanding
(MOU). The MOU outlined a basis for a settlement of all
outstanding cattle partnership cases pending before the Court for
the 1980 through 1986 tax years. The MOU included a basis of
settlement for the SGE partnership with respect to its 1985 and
1986 tax years.
After memorializing the MOU, the parties were unable to
reach an agreement on settlement documents reflecting the terms
outlined in the MOU. As a result, on or about October, 14, 1994,
the parties jointly moved to consolidate several of the cattle
partnership cases, including docket Nos. 22069-89 and 21954-90,
for trial, briefing, and opinion.
On November 20, 1996, the Court issued its opinion with
respect to the consolidated cases resulting from the MOU. See
Shorthorn Genetic Engg. 1982-2, Ltd. v. Commissioner, T.C. Memo.
1996-515. The Court held that the settlement agreement reflected
in the MOU was binding on the parties. Accordingly, on November
27, 1996, the Court entered orders and decisions reflecting its
determinations with respect to the 1985 and 1986 tax years of
SGE.
On January 29, 1997, the following documents were filed in
the consolidated cases: (1) A motion for leave to file out of
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