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on their returns, and petitioner questioned the legitimacy of the
large losses that were reported, but both petitioner and Mr.
Capehart signed the returns anyway.
The Hoyt Partnership Litigation and Settlement
The Commissioner initiated audits of the Hoyt partnerships,
including, but not limited to, SGE, and sent appropriate notices
to the partners, including petitioner and Mr. Capehart.7 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.
7For example, on Sept. 22, 1986, the IRS sent petitioner and
Mr. Capehart a letter informing them that the IRS was examining
SGE with respect to its 1983 taxable year.
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