Gary D. and Johnean F. Hansen - Page 2

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          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          the attached exhibits (excluding those withdrawn at trial) are              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 his              






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