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decision in this case are, with respect to petitioner alone: (1)
Whether petitioner is liable for the section 6653 addition to tax
for negligence in each year in issue; (2) whether petitioner is
liable for the section 6659 addition to tax for valuation
overstatements in each year; (3) whether petitioner is liable for
the increased rate of interest under section 6621(c) that is
applied with respect to tax motivated transactions; and (4)
whether petitioner is entitled to relief from joint and several
liability pursuant to section 6015.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The first, second, third, and fourth stipulation of facts and the
attached exhibits are incorporated herein by this reference.
Petitioner resided in Placerville, California, on the date the
petition was filed in this case.
I. Walter J. Hoyt, III and River City Ranches #1
The parties stipulated certain facts for purposes of this
case that provide a background for the partnership items on
petitioner’s return, facts that concern Walter J. Hoyt, III (Mr.
Hoyt) and the partnership River City Ranches, also known as River
City Ranches #1 (RCR #1). The following is a summary of a
portion of the stipulated facts that are supported by the record:
Mr. Hoyt’s father was a prominent breeder of Shorthorn
cattle, one of the three major breeds of cattle in the United
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