- 5 -
OPINION OF THE SPECIAL TRIAL JUDGE
GOLDBERG, Special Trial Judge: Respondent issued a notice
of final partnership administrative adjustment (FPAA) to each
partnership involved in these consolidated cases determining
adjustments for the taxable years at issue.2 From 1981 through
1998, Walter J. Hoyt III (Jay Hoyt) promoted these nine sheep
breeding partnerships to numerous investors and managed
partnership operations. For convenience, these partnerships are
hereinafter sometimes referred to as the Hoyt sheep partnerships
and these consolidated cases are referred to in the singular
(i.e., instant case). In addition, the individual partners in
the sheep partnerships are collectively referred to as sheep
partners.
On June 22, 1999, the Court issued its opinion in River City
2 The years at issue for River City Ranches #1 are 1986 and
its years ended Sept. 30, 1991 through 1996. The years at issue
for River City Ranches #2 are 1986 and 1987, its year ended Sept.
30, 1991, and its years ended Sept. 30, 1993 through 1996. The
years at issue for River City Ranches #3 are 1986 and 1987, its
years ended Sept. 30, 1989 through 1991, and its years ended
Sept. 30, 1993 through 1996. The years at issue for River City
Ranches #4 are 1984 and 1986, and its years ended Sept. 30, 1992
through 1996. The years at issue for River City Ranches #5 are
1986, 1987 and 1988, and its years ended Sept. 30, 1989 through
1996. The years at issue for River City Ranches #6 are 1986 and
its years ended Sept. 30, 1992 through 1996. The years at issue
for River City Ranches 1985-2/River City Ranches #7 are 1987 and
1988, and its years ended Sept. 30, 1989 through 1996. (In 1991,
River City Ranches 1985-2 became known as River City Ranches #7.)
The years at issue for Ovine Genetic Technology Syndicate 1987-1
are its years ended Sept. 30, 1990 through 1996. The years at
issue for Ovine Genetic Technology 1990 (OGT 90) are 1992, 1993,
1994, 1995, and 1996.
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