- 12 - 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, adjustments to the Hoyt partnerships’ proportionate shares of losses generated from the acquisition, management, and sale of Hoyt cattle were required, and the recalculated losses were deductible by the limited partners to the extent of the partners’ adjusted bases. The settlement agreement, which was executed after we issued Bales in 1989, provided, in pertinent part, as follows: • deductions for contributions to an Individual Retirement Arrangement -- also called an Investment Retirement Account -- are limited to cash actually paid to custodial banks on or before the due date of the return for which the deduction is to be claimed. * * * * * * * • The total number of cattle in service and subject to depreciation by the investor partnerships in each of the following respective years is 1980 -- 1,736 1981 -- 2,463 1982 -- 2,388 1983 -- 2,932 1984 -- 3,476 1985 -- 4,024 1986 -- 6,409 • For Federal income tax purposes, all the cattle are adult breeding cattle, each having an original depreciable basis of $4,000. • The number of cattle to be depreciated during any year will be determined by the following method:Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011