- 12 - 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.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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