- 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 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 are incorporated herein by this reference. Petitioners resided in Sandy, Utah, 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 adjustments of partnership items on petitioners’ 1991 Federal income tax return. The adjustments are the result of petitioners’ involvement in a partnership 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 thePage: 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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