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pooling account were then allocated to the various Hoyt entities
based on a percentage determined by a pooling committee
administered by Jay Hoyt. The duration of the pooling account
cannot be determined by the record. During the years at issue,
substantial sums were deposited into and withdrawn by check from
both the RCR account and the pooling account.
At the end of 1993 or early 1994, the sheep partnerships’
promissory notes and share-crop management agreements were
assigned to MLP. From that point on, MLP was responsible for
providing the various functions that were previously the
responsibility of Barnes Ranch.
C. Respondent’s Examination Efforts and Enforcement Actions
Since approximately 1980, the IRS regularly examined many of
the partnership returns of the Hoyt cattle partnerships and the
individual returns of their partners. The IRS also examined the
sheep partnerships’ returns and the individual returns of their
partners. Because Jay Hoyt did not maintain separate bank
accounts and accurate accounting records for each of the sheep
partnerships, the IRS audited the partnership tax returns as a
group. The IRS generally disallowed the partnership tax benefits
that each cattle and sheep partnership and their respective
partners claimed, resulting in those partnerships and partners
commencing numerous cases in the Tax Court.
The Tax Court litigation over the years concerning the Hoyt
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