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cattle and sheep partnerships includes: (1) Bales v.
Commissioner, T.C. Memo. 1989-568; River City Ranches #4, J.V. v.
Commissioner, T.C. Memo. 1999-209, affd. 23 Fed. Appx. 744 (9th
Cir. 2001); and Durham Farms #1, J.V. v. Commissioner, T.C. Memo.
2000-159, affd. 59 Fed. Appx. 952 (9th Cir. 2003), three test
cases dealing with partnership adjustments; (2) numerous other
cases involving the 1980 through 1986 taxable years of Hoyt
cattle partnerships and their partners that essentially were
resolved after respondent and Jay Hoyt entered into a memorandum
of understanding (MOU) on May 20, 1993, which outlined a basis
for a settlement of all outstanding cattle partnership cases for
the 1980 through 1986 taxable years; and (3) the instant case
involving the nine Hoyt sheep partnerships.
From 1984 through 2000, the IRS’s tax enforcement efforts
with respect to the tax shelter program operated by Jay Hoyt
included: (1) Examinations of the returns of the cattle and
sheep partnerships and their partners; (2) disallowance of the
partnership tax benefits that were claimed; (3) issuance of
prefiling notices to partners and freezing tax refunds they
claimed; and (4) defending litigation commenced in the Tax Court
by partnerships and partners over the adjustments determined in
the FPAAs and notices of deficiency issued by respondent.
From the IRS examinations of the returns of all the cattle
and sheep partnerships and investor-partners through this Tax
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