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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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