McDONOUGH v. COMMISSIONER

Dkt. No. 15239-04.

93 T.C.M. 1145 (2007)

T.C. Memo. 2007-101

Gary W. McDonough v. Commissioner.

United States Tax Court.

April 25, 2007.


Attorney(s) appearing for the Case

Wendy S. Pearson, Terri A. Merriam, Jennifer A. Gellner, Jaret R. Coles, Asher B. Bearman, and Brian G. Isaacson, for petitioner.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 disallowed partnership losses claimed for 1989 and 1991 by Timeshare Breeding Service 1989-1, J.V. (TBS 89-1), a cattle partnership organized, promoted, and operated by Walter J. Hoyt III (Hoyt).2 Petitioner was a partner in TBS 89-1, and he reported his distributive shares of its reported losses on his 1989 and 1991 Federal...

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