- 33 - In River City Ranches II, the Court of Appeals held that the partnerships were entitled to discovery of respondent’s central Hoyt files to find out the facts concerning Hoyt’s interests in his dealings with respondent and what respondent knew about Hoyt’s interests and his treatment of the partners’ interests. River City Ranches #1 Ltd. v. Commissioner, 401 F.3d at 1141, 1143. Pursuant to the mandate of the Court of Appeals, we granted petitioners’ motions to take the depositions of Jill Page, Sue Hullen, and Norman Johnson, present or former IRS employees whom petitioners had called as witnesses during the 2001 trial of these cases. Petitioners took their depositions in April 2006. In order to make further information available to petitioners, respondent went beyond the Court of Appeals’ direction regarding limited additional discovery and made available to petitioners his entire store of documents that had not been produced earlier. This consisted of approximately 160 boxes of documents and 700 linear feet of IRS central Hoyt files. After the discovery sought by petitioners was completed, the Court held a second trial on September 11 and 12, 2006. A. Waivers Executed by Hoyt in March 1993 Are Invalid In River City Ranches I, we analogized these cases to Phillips v. Commissioner, 272 F.3d 1172 (9th Cir. 2001), affg. 114 T.C. 115 (2000), in which the Court of Appeals held that thePage: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 NextLast modified: November 10, 2007