Ronald F. and Cynthia G. Van Scoten - 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 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 the             






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