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HOYT AND SONS RANCH PROPERTIES LTD. NV v. COMMISSIONER

Docket No. 12613-00.

82 T.C.M. 809 (2001)

T.C. Memo. 2001-282

Hoyt and Sons Ranch Properties Ltd. NV, Shorthorn Genetic Engineering 1984-5, J.V., A Partner Other Than the Tax Matters Partner v. Commissioner.

United States Tax Court.

Filed October 11, 2001.

Attorney(s) appearing for the Case

Montgomery W. Cobb, for the petitioner. Thomas N. Tomashek and Alan E. Staines, for the respondent.

MEMORANDUM OPINION

DAWSON, Judge.

This case was assigned to Special Trial Judge Stanley J. Goldberg pursuant to Rules 180, 181, and 183. Unless otherwise indicated, section references herein are to the Internal Revenue Code in effect for the year in issue, and Rule references are to the Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the Special Trial Judge's opinion, which is set forth below.

OPINION OF THE SPECIAL TRIAL...

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