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list the following under the area for partner’s name: “Ernest F.
& Ann E. Bartak”.6
In 1984, petitioner and Mr. Bartak applied for a refund of
their 1980, 1981, and 1982 taxes in the amounts of $3,714,
$4,709, and $5,580, respectively.
On March 10, 1998, respondent mailed petitioner and Mr.
Bartak a letter and report explaining computational adjustments
made to their 1980, 1981, 1982, 1983, 1984, 1985, and 1986
returns as a result of adjustments made to the partnership
returns of SGE 1983-1 for 1984, 1985, and 1986. These
computational adjustments resulted from the Court’s opinion in
Shorthorn Genetic Engg. 1982-2, Ltd. v. Commissioner, T.C. Memo.
1996-515.
Shorthorn Genetic Engg. 1982-2, Ltd. v. Commissioner
Petitioner and Mr. Bartak filed a notice of election to
participate in one of the dockets (28383-89) of Shorthorn Genetic
Engg. 1982-2, Ltd. v. Commissioner, supra, filed a joint motion
to consolidate for trial, briefing, and opinion in that case, and
6 This is also true for Schedules K-1, Partner’s Share of
Income, Credits, Deductions, etc., issued by various Hoyt
partnerships to petitioner and Mr. Bartak in the years subsequent
to the years in issue (1987 through 1996), although some of the
Schedules K-1 do not contain their middle initials and on some
the word “and” is spelled out. Again, we make no finding that
petitioner and Mr. Bartak actually invested in the Hoyt
partnerships in 1983.
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