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DANIEL v. COMMISSIONER

Dkt No. 14819-04.

93 T.C.M. 1190 (2007)

T.C. Memo. 2007-110

Daniel and Kristen Panice v. Commissioner.

United States Tax Court.

April 30, 2007.

Attorney(s) appearing for the Case

Wendy S. Pearson, Terri A. Merriam, Jennifer A. Gellner, Jaret R. Coles, and Asher B. Bearman, for petitioners.1

Nhi T. Luu and Catherine Caballero, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge.

This is an affected items proceeding arising from a disallowed partnership loss claimed for 1992 by Timeshare Breeding Service 1990-1, J.V. (TBS 90-1), a cattle partnership organized, promoted, and operated by Walter J. Hoyt III (Hoyt).2 Petitioners participated in TBS 90-1, and they reported their distributive share of its reported ordinary loss on their 1992 Federal income...

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