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valuation overstatements under section 6621(c)(3)(A)(i), nor sham
or fraudulent transactions under section 6621(c)(3)(A)(v).
On July 16, 2001, during the trial in the instant case,
respondent filed a motion to dismiss this section 6621(c) issue
for lack of jurisdiction, together with a memorandum of points
and authorities in docket No. 9550-94. The Court took the matter
under advisement. On August 3, 2001, respondent filed identical
motions, together with memoranda of points and authorities in
docket Nos. 787-91, 4876-94, 9552-94, 9554-94, 13597-94, 13599-
94, and 14038-96. The Court took these motions under advisement.
Petitioners timely filed their objections to respondent’s motions
to dismiss. The parties then filed their respective posttrial
briefs in the instant case, in which they have addressed the
section 6621(c) issue and respondent’s motions to dismiss.
Petitioners contend that this Court does have jurisdiction
in these partnership level proceedings to determine whether or
not the transactions involving the sheep partnerships are
attributable to tax-motivated transactions for purposes of
section 6621(c). Petitioners assert that these transactions are
neither valuation overstatements as defined in section
6621(c)(3)(A)(i), nor are they sham or fraudulent transactions as
defined in section 6621(c)(3)(A)(v). Among other things,
petitioners maintain that if these transactions were shams, they
were part of a fraud perpetrated by Jay Hoyt upon the partners
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