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Petitioner obtained a copy of the Bales Memorandum Opinion
from another fireman. Petitioner read that Memorandum Opinion,
and he read other related materials provided by Hoyt. Petitioner
never took the Bales Memorandum Opinion to a tax professional
independent of the Hoyt organization for advice.
7. Durham Farms #1
On April 18 and August 15, 1994, respectively, respondent
mailed to petitioner an NBAP and notice of final partnership
administrative adjustment (FPAA) relating to the 1989 taxable
year of TBS 89-1. On May 8, 1995, respondent issued to Hoyt, as
the tax matters partner (TMP) of TBS 89-1, an FPAA for the 1991
taxable year of TBS 89-1. In response to these FPAAs, Hoyt, as
TMP of TBS 89-1, petitioned the Court on October 14, 1994, and
August 4, 1995. The Court docketed the respective cases at our
docket Nos. 18707-94 and 14712-95.
The Court decided the disputed issues underlying those
petitions in a partnership proceeding. See Durham Farms #1, J.V.
v. Commissioner, T.C. Memo. 2000-159, affd. 59 Fed. Appx. 952
(9th Cir. 2003). The Court held that various partnerships,
including TBS 89-1, did not receive the benefits and burdens of
ownership of the cattle in dispute there and were not entitled to
the claimed partnership deductions and losses. On April 24,
2001, the Court entered decisions in Timeshare Breeding Serv.
1989-1, J.V. v. Commissioner, docket No. 18707-94, and Timeshare
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