River City Ranches #1 Ltd., Jeffry Bergamyer, Tax Matters Partner - Page 23

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          benefits that the partners claimed on their individual returns              
          from the cattle and sheep partnerships; and (2) not issue any tax           
          refunds these partners might claim attributable to such                     
          partnership tax benefits.                                                   
               Following respondent’s issuance of prefiling notices to the            
          partners in February 1993 and the completion of the count and               
          inspection of the livestock in May or June 1993, the Examination            
          Division on or about December 30, 1993, issued letters to all the           
          partners in which it warned them that IRS personnel had concluded           
          and determined that:  (1) A number of fictitious breeding cattle            
          and sheep had been sold to the Hoyt cattle and sheep                        
          partnerships; and (2) Hoyt and the Hoyt organization had                    
          overstated both the numbers and value of the purported livestock            
          that the partnerships allegedly owned.                                      
               Respondent eventually issued:  (1) Notices of deficiency to            
          numerous investor-partners for the 1980, 1981, and 1982 tax                 
          years, in which respondent determined that none of the tax                  
          benefits the partners claimed from the cattle and sheep                     
          partnerships were allowable; and (2) FPAAs to many of the cattle            
          and sheep partnerships for the taxable years 1983, 1984, 1985,              
          and 1986, in which respondent disallowed the tax benefits these             
          partnerships claimed.  On December 20, 1993, respondent issued              
          FPAAs to RCR #2 for its tax year ending December 31, 1987, to RCR           
          #3 for its tax years ending December 31, 1987, and September 30,            

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