Ingrid Capehart - Page 11

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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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