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overpayments of tax and received refunds of $14,517 and $10,674,
respectively.
Petitioner carried back unused investment credits derived
from his investment in DGE 85-5 to 1982, 1983, and 1984 and
received refunds of $11,556, $5,059, and $7,637, respectively.
Petitioner also carried forward unused investment credits to 1987
and 1988 of $2,914 and $312, respectively. Using those
investment credits, deductions related to DGE 85-5, and other
deductions, petitioner reported overpayments and received refunds
of $7,045 and $1,306.
On June 13, 1989, respondent issued DGE 85-5 a notice of
final partnership administrative adjustment (FPAA) for its 1985
tax year. On October 1, 1990, respondent issued DGE 85-5 an FPAA
for its 1986 tax year. Respondent disallowed all losses and cost
bases in “property eligible for investment credit” claimed by DGE
85-5 and asserted that additions to tax under sections 6653(a)(1)
and (2), 6659, and 6661 and increased interest under section
6621(c) applied to the individual partners.
Hoyt, as the tax matters partner for DGE 85-5, filed
petitions with the Tax Court in response to the FPAAs.6 DGE 85-
5’s cases were consolidated with other Hoyt partnerships’ cases
in 23 separate docket numbers. See Shorthorn Genetic Engg. 1982-
6 The petition in response to the 1985 FPAA was filed at
docket No. 22070-89, and the petition in response to the 1986
FPAA was filed at docket No. 28577-90.
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