- 2 - effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The sole issue for decision is whether petitioners are liable for the section 6662(a) accuracy-related penalty for negligence or disregard of rules or regulations in the year in issue. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The first, second, third, and fourth stipulations of facts and the attached exhibits (excluding those withdrawn at trial) are incorporated herein by this reference. Petitioners resided in Kennewick, Washington, on the date the petition was filed in this case. I. Walter J. Hoyt III and the Hoyt Partnerships The accuracy-related penalty at issue in this case arises from an adjustment of a partnership item on petitioners’ 1991 Federal income tax return. This adjustment is the result of petitioners’ involvement in certain partnerships organized and promoted by Walter J. Hoyt III (Mr. Hoyt). Mr. Hoyt’s father was a prominent breeder of Shorthorn cattle, one of the three major breeds of cattle in the United States. In order to expand his business and attract investors, Mr. Hoyt’s father had started organizing and promoting cattle breeding partnerships by the late 1960s. Before and after hisPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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