River City Ranches #1 Ltd., Leon Shepard, Tax Matters Partner - Page 6

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          Ranches #4, J.V. v. Commissioner, T.C. Memo. 1999-209, affd. 23             
          Fed. Appx. 744 (9th Cir. 2001), a test case in which the Tax                
          Court upheld respondent’s disallowance of all deductions that               
          three Hoyt sheep partnerships claimed for taxable years not at              
          issue in the instant cases.3                                                
               After concessions,4 the primary issues for decision in the             
          instant cases (which petitioners raised in amended petitions)               
          are:  (1) Whether the nine Hoyt sheep partnerships are entitled             
          to theft loss deductions under section 165 for each of the years            
          at issue equal to the total cash payments made by the partners in           
          each such year to the partnerships; (2) whether the period of               
          limitations provided under section 6229 expired prior to the time           
          that respondent issued FPAAs to some partnerships for certain               
          taxable years; and (3) whether purported purchases of breeding              
          sheep that some partnerships reported for pre-1989 taxable years            
          constitute either (a) “valuation overstatement” as defined in               


               3  River City Ranches #4, River City Ranches #6, and OGT 90            
          were the partnerships at issue in this test case.  The taxable              
          years decided were:  For River City Ranches #4, 1987 and 1988,              
          and its years ended Sept. 30, 1989 through 1991; and for River              
          City Ranches #6, 1987 and 1988, and its years ended Sept. 30,               
          1989 through 1991.  For OGT 90 the year decided was 1991.                   
               4  The parties have resolved all of the adjustments in each            
          notice of final partnership administrative adjustment issued to             
          each of the nine sheep partnerships.  Among other things,                   
          petitioners now agree that the sheep partnerships did not acquire           
          the benefits and burdens of ownership of any sheep and that the             
          promissory note each partnership issued in connection with its              
          purported acquisition of sheep is not a valid indebtedness.                 





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