River City Ranches #1 Ltd., Leon Shepard, Tax Matters Partner - Page 33

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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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