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Partnership Year Docket No.
RCR #2 1987 4876-94
RCR #3 1987 9550-94
1989 13595-94
RCR #4 1984 14038-96
RCR #5 1987 9552-94
1988, 1989 13597-94
RCR 85-2 1987 9554-94
1988, 1989 13599-94
In deciding this issue we must decide whether the consents to
extend the periods of limitations were invalid because Hoyt
signed them while disabled by conflicts of interest known to
respondent. Alternatively, if the consents were invalid, we must
decide whether the 6-year period of limitations on assessment
under section 6229(c)(1) applies because of fraud.5
5In the second amendment to the answer, respondent raised
the application of the 6-year period of limitations on assessment
under sec. 6229(c)(1) as an alternative to the argument that the
consents were valid. The issue was tried and briefed in River
City Ranches I. In River City Ranches I, we held that
petitioners did not prove that the consents were invalid and,
therefore, we did not decide whether the 6-year limitations
period under sec. 6229(c)(1) applied. The parties have briefed
the issue again on remand.
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Last modified: November 10, 2007