River City Ranches #1 Ltd., Leon Shepard, Tax Matters Partner - Page 37

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               Based on the above conclusions from its count of the cattle            
          and sheep, the IRS, beginning in February 1993, generally froze             
          and stopped issuing income tax refunds to partners in the cattle            
          and sheep partnerships.  The IRS issued prefiling notices to the            
          investor-partners advising them that, starting with the 1992                
          taxable year, the IRS would (1) disallow the tax benefits that              
          the partners claimed on their individual returns from the cattle            
          and sheep partnerships and (2) not issue any tax refunds these              
          partners might claim attributable to such partnership tax                   
          benefits.10                                                                 
               Respondent eventually issued:  (1) Notices of deficiency to            
          numerous investor-partners for the 1980, 1981, and 1982 tax                 
          years, in which respondent determined that none of the tax                  
          benefits the partners claimed from the cattle and sheep                     
          partnerships were allowable; and (2) FPAAs to many of the cattle            
          and sheep partnerships for the taxable years 1983, 1984, 1985,              
          and 1986, in which respondent disallowed the tax benefits these             
          partnerships claimed.                                                       
               Following the IRS’s freezing in February 1993 of tax refunds           
          to partners in the cattle and sheep partnerships, the Hoyt                  
          organization experienced financial difficulties.  Freezing the              


               10  Ultimately, this Court, in Durham Farms #1, J.V. v.                
          Commissioner, T.C. Memo. 2000-159, and River City Ranches #4,               
          J.V. v. Commissioner, T.C. Memo. 1999-209, upheld respondent’s              
          disallowance of almost all tax benefits claimed by those cattle             
          and sheep partnerships for certain post-1986 taxable years.                 





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