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cattle partnerships, the sheep partnerships, and other similar
partnerships that Hoyt promoted. The fraud perpetrated by Hoyt
“impacted over 4,000 people and had actual and intended losses
exceeding $200 million.” United States v. Hoyt, supra at 837.
OPINION
Issue 1. Whether Partnership Transactions and the Sheep
Partnerships Lacked Economic Substance and Were Shams,
and Whether There Were Partnership Asset Overvaluations
and Basis Overvaluations
The Court of Appeals reversed our holding in River City
Ranches I that we lacked jurisdiction to make factual findings as
to whether the partnerships’ transactions were tax-motivated for
purposes of imposing section 6621(c) penalty-interest against
investor-partners. Thus, the Court of Appeals remanded for us to
make such findings. We have done so in our supplemental factual
findings set forth herein.
We point out that many of the key facts have been stipulated
by the parties and are so found. Furthermore, our prior opinion
in River City Ranches #4, J.V. v. Commissioner, T.C. Memo. 1999-
209, supports the conclusion that the activities of these
partnerships lacked economic substance and were shams for each of
the years of their existence. The findings in that case are
equally applicable to these cases because the facts and evidence
with respect to these partnerships’ breeding activities are the
same as the facts and evidence considered there. While the
proceeding in River City Ranches #4, J.V. involved only three of
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