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          partnership property from each of the sheep partnerships.                    
          Petitioners rely on Jay Hoyt’s Federal conviction and three                  
          Oregon statutes that are similar to the Federal criminal statutes            
          Jay Hoyt was convicted of violating as proof of the occurrence of            
          a theft from the partnerships.  On the premise that Jay Hoyt’s               
          conviction establishes a theft from the individual investors,                
          petitioners claim that the partnerships were the victims of Jay              
          Hoyt’s theft, because “a theft from all the partners, is a theft             
          from the partnerships.”  Finally, petitioners cite various cases             
          for propositions that they assert establish a theft from the                 
          partnerships.                                                                
               The Court is mindful that throughout all of petitioners’                
          arguments dealing with a theft loss, they treat “partners” and               
          “partnerships” as the same, making no clear distinction between              
          these terms.  As set forth infra pp. 51-55, a clear distinction              
          exists under both California and Nevada law.  Further, a                     
          distinction between partners and partnerships exists under                   
          Federal law.  See sec. 6226.                                                 
               Because all the partnerships at issue are subject to the                
          provisions enacted in the Tax Equity & Fiscal Responsibility Act             
          of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 648, our              
          jurisdiction is limited exclusively to the determination of the              
          tax treatment of partnership items for the partnership year to               
          which the FPAA relates.  See sec. 6226; infra pp. 108-109.  We               
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