John M. Mekulsia - Page 12

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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               
               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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