- 2 -
effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
The sole issue before this Court is whether petitioner is
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 are incorporated herein by this reference.
Petitioner resided in Hixson, Tennessee, 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 petitioner’s 1991
Federal income tax return. This adjustment is the result of
petitioner’s 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
father’s death in early 1972, Mr. Hoyt and other members of the
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011