Susan L. Abelein - Page 12

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          the partners, including petitioner and Mr. Abelein.6  Mr. Hoyt,             
          the tax matters partner for the partnerships, represented the               
          Hoyt partnerships during the audits.                                        
               As a result of the audits, the Commissioner proposed                   
          adjustments to the Hoyt partnership tax returns.  The Hoyt                  
          partnerships filed petitions in this Court to contest the                   
          partnership adjustments.  The partnership-level proceedings were            
          resolved as a result of our opinions in Shorthorn Genetic Engg.             
          1982-2, Ltd. v. Commissioner, T.C. Memo. 1996-515, and Bales v.             
          Commissioner, T.C. Memo. 1989-568 (involving 26 dockets filed by            
          partners in similar Hoyt partnerships that were tried as test               
          cases and covered taxable years before 1982), and a memorandum of           
          understanding between the IRS and Mr. Hoyt dated May 20, 1993               
          (the settlement agreement), that set forth the basis for settling           
          all Hoyt cattle partnership cases for 1980 through 1986.                    
               In Bales v. Commissioner, supra, we held, inter alia, that             
          although the Hoyt partnerships at issue were not lacking in                 
          economic substance and would be respected for tax purposes,                 


               6For example, on Sept. 26, 1988, respondent sent petitioner            
          and Mr. Abelein a notice of beginning of an administrative                  
          proceeding at the partnership level concerning the audit of DGE             
          for the taxable year 1986.  On Nov. 21, 1988, respondent sent               
          petitioner and Mr. Abelein a notice of beginning of an                      
          administrative proceeding at the partnership level concerning the           
          audit of DGE for the taxable year 1985.  On Oct. 1, 1990,                   
          respondent sent petitioner and Mr. Abelein a notice of final                
          partnership administrative adjustment concerning the audit of DGE           
          for the taxable year 1986.                                                  





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