Helen E. Foy - Page 4

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          their partnership units jointly and titled their partnership                
          interests as joint tenancies with right of survivorship.                    
          Petitioner wrote numerous checks to the Hoyt organization, and              
          the Hoyt organization issued Schedules K-1 (Form 1065), Partner’s           
          Share of Income, Credits, Deductions, etc., with respect to SGE             
          1984-3, DSBS 1987-4, and TBS JV to petitioner and Mr. Foy                   
          jointly.                                                                    
               Petitioner and Mr. Foy filed joint Federal income tax                  
          returns for 1981 through 1986 on which they claimed substantial             
          losses and an investment credit related to their investment in              
          SGE 1984-3.  Following an audit and related litigation,4                    
          respondent adjusted the Hoyt partnership losses and investment              
          credit claimed on petitioner and Mr. Foy’s 1981-1986 tax returns            
          and assessed substantial income tax deficiencies.                           


               3(...continued)                                                        
          The investors in the Hoyt partnerships assumed personal liability           
          for the partnerships’ promissory notes, made payments on the                
          notes to the Hoyt partnerships, see, e.g., Shorthorn Genetic                
          Engg. 1982-2, Ltd. v. Commissioner, supra, and, in return,                  
          deducted large partnership losses related to the purchase,                  
          management, and sale of livestock, see River City Ranches #1,               
          Ltd. v. Commissioner, supra; Mekulsia v. Commissioner, T.C. Memo.           
          2003-138, affd. 389 F.3d 601 (6th Cir. 2004); Durham Farms #1,              
          J.V. v. Commissioner, supra; Shorthorn Genetic Engg. 1982-2, Ltd.           
          v. Commissioner, supra; Bales v. Commissioner, T.C. Memo 1989-              
          568.                                                                        
               4According to respondent, the litigation regarding                     
          petitioner and Mr. Foy’s investment in SGE 1984-3 was resolved by           
          this Court’s order and decision, entered on Nov. 27, 1996, in               
          Shorthorn Genetic Engg. 1984-3, Ltd. v. Commissioner, docket No.            
          24514-89.                                                                   




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