The opinion
T.C. Memo. 1996-495
UNITED STATES TAX COURT
WASHOE RANCHES #1, LTD., WASHOE RANCHES #2, LTD., WASHOE RANCHES
#3, LTD., WASHOE RANCHES #4, LTD., WASHOE RANCHES #5, LTD.,
WASHOE RANCHES #6, LTD., WASHOE RANCHES #7, LTD., WALTER J. HOYT
III, TAX MATTERS PARTNER, ET AL.,1 Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 8916-89, 8935-89, Filed November 4, 1996.
8936-89, 21998-89,
21999-89, 22000-89,
1
The following cases are consolidated herewith: Florin Farms #1, Ltd.,
Florin Farms #2, Ltd., Florin Farms #3, Ltd., Florin Farms #4, Ltd., Florin
Farms #5, Ltd., Florin Farms #6, Ltd., Florin Farms #7, Ltd., Walter J. Hoyt
III, Tax Matters Partner, docket No. 8935-89; Durham Farms #1, Ltd., Durham
Farms #2, Ltd., Durham Farms #3, Ltd., Durham Farms #4, Ltd., Durham Farms #5,
Ltd., Durham Farms #6, Ltd., Walter J. Hoyt III, Tax Matters Partner, docket
No. 8936-89; Florin Farms #1, Ltd., Florin Farms #2, Ltd., Florin Farms #3,
Ltd., Florin Farms #4, Ltd., Florin Farms #5, Ltd., Florin Farms #6, Ltd.,
Florin Farms #7, Ltd., Walter J. Hoyt III, Tax Matters Partner, docket No.
21998-89; Florin Farms #1, Ltd., Florin Farms #2, Ltd., Florin Farms #3, Ltd.,
Florin Farms #4, Ltd., Farms #5, Ltd., Florin Farms #6, Ltd., Florin Farms #7,
Ltd., Walter J. Hoyt III, Tax Matters Partner, docket No. 21999-89; Durham
Farms #1, Ltd., Durham Farms #2, Ltd., Durham Farms #3, Ltd., Durham Farms #4,
Ltd., Walter J. Hoyt III, Tax Matters Partner, docket No. 22000-89; Durham
Farms #1, Ltd., Durham Farms #2, Ltd., Durham Farms #3, Ltd., Durham Farms #4,
Ltd., Walter J. Hoyt III, Tax Matters Partner, docket No. 22073-89; Washoe
Ranches #6, Ltd., Washoe Ranches #7, Ltd., Walter J. Hoyt III, Tax Matters
Partner, docket No. 26720-89; Washoe Ranches #1, Ltd., Washoe Ranches #2,
Ltd., Washoe Ranches #3, Ltd., Washoe Ranches #4, Ltd., Washoe Ranches #5,
Ltd., Walter J. Hoyt III, Tax Matters Partner, docket No. 27676-89; Washoe
Ranches #1, Ltd., Washoe Ranches #2, Ltd., Washoe Ranches #3, Ltd., Washoe
Ranches #4, Ltd., Washoe Ranches #5, Ltd., Walter J. Hoyt III, Tax Matters
Partner, docket No. 27722-89; Durham Farms #5, Ltd., Durham Farms #6, Ltd.,
Walter J. Hoyt III, Tax Matters Partner, docket No. 28133-89; Durham Farms #1,
Ltd., Durham Farms #2, Ltd., Durham Farms #3, Ltd., Durham Farms #4, Ltd.,
Durham Farms #5, Ltd., Durham Farms #6, Ltd., Walter J. Hoyt III, Tax Matters
Partner, docket No. 6211-90; Washoe Ranches #1, Ltd., Washoe Ranches #2, Ltd.,
Washoe Ranches #3, Ltd., Washoe Ranches #4, Ltd., Washoe Ranches #5, Ltd.,
Washoe Ranches #6, Ltd., Washoe Ranches #7, Ltd., Walter J. Hoyt III, Tax
Matters Partner, docket No. 6262-90; Florin Farms #1, Ltd., Florin Farms #2,
Ltd., Florin Farms #3, Ltd., Florin Farms #4, Ltd., Florin Farms #5, Ltd.,
Florin Farms #6, Ltd., Florin Farms #7, Ltd., Walter J. Hoyt III, Tax Matters
Partner, docket No. 7560-90.
- 2 -
22073-89, 26720-89,
27676-89, 27722-89,
28133-89, 6211-90,
6262-90, 7560-90.
Walter J. Hoyt III, pro se.
Margaret Martin, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge: These consolidated cases were assigned to
Special Trial Judge Stanley J. Goldberg pursuant to section
7443A(b)(4) and Rules 180, 181, and 183.2 The Court agrees with
and adopts the opinion of the Special Trial Judge which is set
forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
GOLDBERG, Special Trial Judge: Respondent issued a notice
of final partnership administrative adjustments to each limited
partnership involved in these consolidated cases determining
adjustments in the amounts and for the tax years as set forth in
the Appendix hereto.
Walter J. Hoyt III (petitioner), the tax matters partner for
each of the limited partnerships (partnerships) involved herein,
filed a petition for redetermination of the partnership
adjustments. All issues, except one, have been settled by
stipulation so that the only remaining issue to be decided is
2
Unless otherwise indicated, all section references are to the Internal
Revenue Code in effect for the years in issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
- 3 -
each limited partnership's correct amount of Schedule F income,
if any, to be calculated in accordance with a settlement
agreement (the agreement) dated May 20, 1993, entered into
between Walter J. Hoyt III, and respondent's Sacramento,
California, Appeals Office. At trial, respondent submitted a
motion for entry of decision and a proposed decision document in
each case that includes the Schedule F income. Petitioner
objected to respondent's motion as stated. On the record
respondent recharacterized her motion as a motion for summary
judgment that was filed as such. If we decide that the agreement
provides for the inclusion of Schedule F income, then the parties
agree that the amount of Schedule F income reflected in each
proposed decision document is correct, and that we may enter the
proposed decision document in each case. However, if we decide
that the agreement does not provide for Schedule F income, then
we may enter a decision in each case minus the Schedule F income
shown thereon.
These consolidated cases involved adjustments to partnership
income of Washoe Ranches #1 through #7, Florin Farms #1 through
#7, and Durham Farms #1 through #6 for taxable years ended
December 31, 1983, 1984, 1985, and 1986. All the partnerships
are limited partnerships formed to engage in the business of
cattle breeding.
This Court has previously considered the tax consequences of
the Hoyt family cattle breeding operations in Bales v.
- 4 -
Commissioner, T.C. Memo. 1989-568. The Bales case involved
deficiencies in Federal income taxes of individual limited
partners for the taxable years 1974 through 1980 who had invested
in Florin Farms #1, #2, #3, #4, and #5, Durham Farms #1, #2, #3,
and #4, and Washoe Ranches #1, #2, #3, #4, #5, and #6. As a
result of our opinion in Bales v. Commissioner, supra, on May 20,
1993, Walter J. Hoyt III, the general partner and tax matters
partner, entered into a settlement with respondent's Sacramento,
California, Appeals Office, setting forth the basis of settling
all Hoyt cattle partnership cases for the taxable years 1980
through 1986.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits received into evidence
are incorporated by this reference.
The partnerships purchased the cattle used in their breeding
operations from Hoyt & Sons Ranches (Ranches). In payment for
the cattle purchased, the partnerships executed promissory notes
payable to Ranches. During the taxable years in issue, they
transferred cattle to Ranches in payment of principal and
interest due on the notes. The parties introduced documentary
evidence as to each of these transactions: Bills of sale from
Ranches to the partnerships; promissory notes from them to
Ranches; and bills of sale from them to Ranches.
- 5 -
The partnerships reported income recognized on the transfer
of cattle to Ranches in payment of principal and interest as gain
under section 1231. Respondent adjusted this item to zero on the
final partnership administrative adjustments issued to each
partnership.
Pursuant to the settlement agreement, the numbers of cattle
subject to depreciation by the partnerships for the taxable years
in issue were reduced. All cattle were subject to revised
valuation as well. As a result, the amounts of principal due on
the notes payable to Ranches for the cattle purchased were
reduced, and respondent recalculated the annual interest due
based on these amounts according to the provisions of the
settlement agreement. Such interest was to be computed on an
original principal balance of $4,000, the settled cost basis of
the breeding cattle per head, times the number of cattle in
service during the first year of each partnership.
The pertinent portions of the agreement provide:
The primary purpose of this memorandum is to
memorialize the bases we reached for settling all cases
involving Hoyt Cattle partnerships for the years 1980
through 1986. It is our express intent to apply the
provisions specified in this memorandum to determine the tax
effects on partnership transactions and operations.
* * * * * * *
Satisfaction of obligations for interest, principal payments
and management fees by transferring calves and culled cows
will constitute ordinary income to the investor
partnerships. This convention is consistent with the Tax
Court's decision in Bales v. Commissioner, which provides
that
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-- calves are not section 1231(a) property; and
-- although culled cattle are section 1231(a) property,
the gain on which may be long term capital gain
(depending on the holding period), depreciation allowed
must be recaptured as ordinary income under the
provisions of section 1245.
Principal payments equal to 10% of the face amount of the
notes payable to Ranches will begin according to terms of
the notes -- in the sixth year of the partnership * * *
The agreement includes a provision listing "the total number
of cattle in service and subject to depreciation by the investor
partnerships" for each of the taxable years 1980 through 1986.
The Stipulation of Facts provides, in part:
15. All of the payments on the promissory notes made
by the partnerships to Hoyt & Sons Ranches beginning in the
sixth year after the respective notes were executed were
paid by transferring cattle with a zero basis, rather than
cash. * * *
16. The petitioners agree that all of the figures
shown on the schedules (Joint Exhibits 372-NH) [a schedule
of the interest and principal due for each of the years 1983
through 1986] are correct. The petitioners agree that all
of the interest and principal payments beginning in the
sixth year of the notes were made by the transfers of cattle
rather than cash. * * *
The following terminology is used in the cattle business.
Cattle are classified as calves from birth to weaning; heifer
calves being female calves. After weaning, females are referred
to as heifers or yearling heifers. A heifer that bears a calf is
thereafter a cow. Culled cows are cows that are removed from the
breeding herd because they are suffering performance problems,
such as not producing milk or not breeding. Cows may be culled
due to age.
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OPINION
At trial, respondent filed a motion for summary judgment in
these consolidated cases. Given the disposition of the issue on
the merits as discussed below, we do not find it necessary to
address respondent's motion for summary judgment, and it will be
denied.
Under section 6224 a settlement agreement between respondent
and a tax matters partner related to the determination of
partnership items for any partnership taxable year is binding on
the parties to the agreement with respect to the determination of
partnership items for such partnership taxable year unless there
is a showing of fraud, malfeasance, or misrepresentation of fact.
Sec. 6224(c). Petitioner and respondent both assert that the
agreement is clear and unambiguous, and neither party seeks to
have it set aside. However, the parties do not agree on the
proper interpretation and enforcement of the agreement.
Petitioner argues that the settlement memorandum was a
complete integration of the agreement between petitioners and
respondent and that respondent is precluded from relying on facts
not contained therein. Petitioner argues that because the
agreement limited the number of cattle subject to depreciation,
the agreement failed to provide for the cattle necessary for the
partnerships to make the payments of principal and interest to
Hoyt & Sons Ranches by the transfer of cattle. Petitioner
contends that the provision in the settlement agreement regarding
- 8 -
payments of principal on the notes must be read to include the
intention to make such payments by the transfer of registered
shorthorn heifers. Petitioner further contends that the "cattle"
transferred in payment of the notes, as stipulated, were not
calves or culled cattle but registered shorthorn heifers.
Petitioner argues that the Bales decision and the agreement do
not apply to the type of cattle transferred.
Respondent argues that the terms of the agreement are clear,
limiting only the number of cattle subject to depreciation, not
the total number of cattle. Because petitioner has stipulated
that all principal and some interest payments on the notes were
made by transferring cattle with a zero basis, respondent claims
that these cattle would be nondepreciable or fully depreciated
and not limited in number by the terms of the agreement.
Respondent argues that the partnerships must recognize ordinary
income in the amount of those payments by the terms of the
agreement.
The settlement of tax cases is governed by general
principles of contract law. A settlement agreement is in essence
a contract. Each party agrees to concede some rights which he or
she may assert against his or her adversary as consideration for
those secured in the settlement agreement. Saigh v.
Commissioner, 26 T.C. 171, 177 (1956). In determining the proper
meaning of the terms of the agreement, we look to the language of
the agreement and the circumstances surrounding its execution.
- 9 -
Robbins Tire Co. v. Commissioner, 52 T.C. 420, 435-436 (1969).
Generally, extrinsic evidence will not be admitted to expand,
vary, or explain the terms of a written agreement unless the
agreement is ambiguous. Rink v. Commissioner, 100 T.C. 319, 325
(1993), affd. 47 F.3d 168 (6th Cir. 1995); Woods v. Commissioner,
92 T.C. 776, 780-781 (1989). Petitioner bears the burden of
proving that his interpretation of any ambiguous contract
language is correct. Rule 142(a); Rink v. Commissioner, supra at
326.
The settlement agreement provides that the partnerships must
recognize ordinary income in the amount of any interest and
principal payments made by the transfer of calves. In addition,
they must recognize income on the transfer of any culled cattle
in payment on the notes, and such income will be ordinary in
character to the extent it represents depreciation recapture.
The stipulations provide that the partnerships transferred cattle
with a zero basis in payment on the notes in amounts stipulated.
We interpret this to mean that they transferred calves, culled
cattle, or some combination thereof, to Ranches in payment of
interest and principal due on the notes. Thus we find that the
agreement applies to this transaction. Because their bases in
these cattle were zero, the partnerships must recognize ordinary
income in a manner consistent with the decision in Bales v.
Commissioner, supra, as provided in the agreement and
stipulations. We believe that a reasonable person with knowledge
- 10 -
of the facts and circumstances surrounding the agreement would
interpret the agreement and stipulations in this manner. Thus,
we hold that the agreement provides for the inclusion of Schedule
F income in the amounts shown in respondent's proposed decision
documents.
Petitioner argues that this interpretation is inconsistent
with the other terms of the agreement. An agreement should be
interpreted as a whole, and any writings which are part of the
same transaction should be interpreted together. 2 Restatement,
Contracts 2d, sec. 202 (1981). "An interpretation that gives a
reasonable meaning to all parts of the contract will be preferred
to one that leaves portions of the contract meaningless." Rink
V. Commissioner, 47 F.3d 168, 171 (6th Cir. 1995), affg. 100 T.C.
319 (1993); 2 Restatement, Contracts 2d, sec. 202 (1981); 4
Williston on Contracts, sec. 618 (3d ed. 1961).
Petitioner argues that the agreement limits the total number
and class of cattle held by the partnerships. The provision
establishing the number of cattle held by the partnerships
clearly applies, by its terms, only to depreciable cattle.
Petitioner argues that we should infer from this language that no
other cattle exist. We find this reading to be inconsistent with
other provisions of the agreement.
For example, although not directly relevant to these cases,
the agreement provides that cattle owned by the partnerships as
of January 1, 1980, will be considered fully depreciated at the
- 11 -
end of 1981. Thus the agreement provides that there are cattle
that are no longer subject to depreciation.
In addition, as set out above, the agreement provides that
payments made by the partnerships to Ranches by transfer of
calves or culled cows will constitute ordinary income in a manner
consistent with the decision in Bales v. Commissioner. In that
case the Court stated that dispositions of breeding cattle,
including culled cows, are taxed pursuant to section 1231(a)
subject to the recapture provisions of section 1245. The Court
further stated calves that are used for payment on the notes are
not held for breeding purposes and are not accorded section 1231
treatment. Bales v. Commissioner, T.C. Memo. 1989-568. Such
calves would not be subject to an allowance for depreciation and
thus would not be subject to the limitation on depreciable cattle
set forth above. Cf. sec. 1.167(a)-6(b), Income Tax Regs. If
petitioner's reading were accepted, this provision concerning
calves would be rendered meaningless.
We note that the agreement is not completely clear in all of
its terms. In part, the agreement provides: "For Federal income
tax purposes, all the cattle are adult breeding cattle, each
having an original depreciable basis of $4,000." We do not think
this provision is clear and unambiguous because it could be read
on its own to limit the type of cattle held by the partnerships.
However, we interpret this paragraph as qualifying the one
directly preceding it which limits the number of cattle subject
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to depreciation for each year, and neither party has suggested a
different interpretation. After considering these provisions and
the agreement as a whole, we reject petitioner's argument that
the provision limiting the number of depreciable cattle should be
read to limit the total number of cattle held by the
partnerships.
Even if we found the agreement ambiguous as to this
provision, petitioner has offered no extrinsic evidence that
supports his position. We find that the agreement limited the
number of cattle subject to depreciation only but did not limit
the number of non-depreciable cattle owned by the partnerships.
Petitioner further argues that the portion of the agreement
that provides that principal payments will begin in the sixth
year of the partnership should be enforced by concluding that
such payments are to be made by the transfer of registered
shorthorn heifers. The language of the agreement is silent as to
the method of payment.
Petitioner's proffered evidence, when considered in light of
general contract principles, does not convince us that his
interpretation is correct. When the Court asked petitioner if he
assumed or intended that the provision meant that payment would
be made by the transfer of registered shorthorn heifers, he
responded "I wouldn't characterize it that way". He testified
that he did not designate, in the provision, the class of cattle
with which payment was to be made because he was focusing on
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trying to draft a document for the basis of settlement. We find
that, although the agreement does not provide a specific method
of payment on the notes, the parties have stipulated that the
payments were made by the transfer of cattle.
Ordinarily, a stipulation of fact is binding on the parties,
and the Court is constrained to enforce it. Rule 91. The Court
will not permit a party to a stipulation to qualify, change, or
contradict the stipulation except where justice requires. Rule
91(e). The interpretation of a stipulation is determined
primarily by ascertaining the intent of the parties by applying
rules of contract law. Stamos v. Commissioner, 87 T.C. 1451,
1455 (1986).
As we understand petitioner's argument, he claims that the
"cattle" transferred in payment on the notes as stipulated were
not culled cows or calves but were registered shorthorn heifers
and, therefore, not covered by the agreement. Petitioner argues
that there is no gain to be recognized from the transfers because
the Bales decision does not apply to this class of cattle. We
disagree.
Petitioner has stipulated that the cattle transferred had a
zero basis. Thus the transfers result in ordinary income to the
partnerships regardless of whether the cattle are heifers or
culled cows and calves. A stipulation may be set aside where it
is clearly contrary to the facts disclosed on the record. Cal-
Maine Foods, Inc. v. Commissioner, 93 T.C. 181, 195 (1989). The
- 14 -
evidence offered by petitioner consists of bills of sale from the
partnerships to the Ranches corresponding to the cattle that
petitioner claims were transferred in payment on the notes. The
bills refer to the cattle as "registered shorthorn heifers". The
bills of sale do not indicate the partnerships' basis in any of
the cattle. The facts in this record do not show that the
partnerships made payment on the notes with cattle other than
those with a zero basis as stipulated. Accordingly, they must
recognize gain in the amounts of the payments of interest and
principal on the notes.
Petitioner's argument concerning the terms of the agreement
and stipulation is not entirely clear, and we will briefly
address the alternate argument we think he may be attempting to
make. The argument can be summarized as follows. The agreement
sets out the number of cattle subject to depreciation on an
annual basis. As stated in the petition, the partnerships sold
registered shorthorn heifers that had been held for breeding
purposes for over 24 months in payment of the notes. These
cattle would be depreciable. Because the number of cattle
subject to depreciation does not decrease in correlation to the
cattle transferred in payment on the notes, the agreement does
not provide the partnerships with sufficient cattle to make such
payments. Therefore, the payments could not have been made under
the binding terms of the agreement.
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We are not persuaded by this argument. Even if the cattle
transferred were depreciable registered shorthorn heifers,
petitioner has stipulated that the cattle had zero basis, and as
explained above, we will not set aside this stipulation.
Therefore, the cattle would be fully depreciated and outside of
the provision limiting the number of cattle held subject to
depreciation.
In the alternative, petitioner argues that because
respondent calculated lower interest payable by the partnerships
for the years in issue consistent with the agreement, in some of
the years they paid cash to Hoyt & Sons Ranches in excess of the
amounts due. This cash, petitioner asserts, should be applied to
any future principal and interest due on the notes payable to
Hoyt & Sons Ranches before the partnerships recognize any
ordinary income on the transfer of cattle in payment.
Respondent argues that the stipulation clearly negates any
claim that the partnerships made payments on the notes with cash,
and that they are bound by the stipulation.
The Court will hold the parties bound by a stipulation
unless justice requires otherwise. Rule 91(e). The Court may
modify or set aside a stipulation which is clearly contrary to
the facts revealed on the record. Cal-Maine Foods v.
Commissioner, supra.
Petitioner attached schedules entitled "Partnerships Cash
Reconciliation" to petitioner's posttrial brief for each of the
- 16 -
years 1980 through 1986. This exhibit is not considered to be
evidence. Rule 143(b). Petitioner also argues that the
stipulations entered in another case are evidence in support of
his position. Stipulations have effect in the cases only in
which they are entered and are not binding for any other purpose.
Rule 91(e). Therefore, the stipulations from the other cases are
not evidence in these cases.
Petitioner has offered no other evidence to show that any
cash was paid to Hoyt & Sons Ranches. The only evidence
introduced by petitioner are the bills of sale detailing the
number of cattle transferred as payment on the notes. Moreover,
petitioner stipulated that the payments at issue were made by
transferring cattle, not cash. This stipulation is not clearly
contrary to the facts disclosed on the record. Therefore, we
find that the partnerships made interest and principal payments
beginning in the sixth year of the notes payable by transferring
cattle. They must recognize ordinary income on the transfer of
cattle in the amounts stipulated.
To reflect the foregoing,
An appropriate order and decision
will be entered in each case.
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APPENDIX
Taxable Adjustments
Year Investment Ordinary Separately Stated
Docket No. Partnership Ending Tax Credit Income Partnership Items
8916-89 Washoe Ranches #1, LTD. 11-30-85 $11,895 $218,117 $485,223
" " 12-31-85 11,895 218,117 485,223
Washoe Ranches #2, LTD. 11-30-85 11,896 79,469 265,669
" " 12-31-85 11,896 79,469 265,669
Washoe Ranches #3, LTD. 11-30-85 11,895 91,326 240,251
" " 12-31-85 11,895 91,326 240,251
Washoe Ranches #4, LTD. 11-30-85 11,896 158,182 369,043
" " 12-31-85 11,896 158,182 369,043
Washoe Ranches #5, LTD. 11-30-85 11,895 219,965 335,823
" " 12-31-85 11,895 219,965 335,823
Washoe Ranches #6, LTD. 11-30-85 11,896 150,593 276,179
" " 12-31-85 11,896 150,593 276,179
Washoe Ranches #7, LTD. 11-30-85 11,895 153,792 431,917
" " 12-31-85 11,895 153,792 431,917
8935-89 Florin Farms #1, LTD. 11-30-85 11,896 24,672 155,143
" " 12-31-85 11,896 24,672 155,143
Florin Farms #2, LTD. 11-30-85 11,896 41,535 206,428
" " 11-30-85 11,896 41,535 206,428
Florin Farms #3, LTD. 11-30-85 11,896 2,216 310,697
" " 12-31-85 11,896 2,216 310,697
Florin Farms #4, LTD. 11-30-85 11,895 13,703 148,332
" " 12-31-85 11,895 13,703 148,332
Florin Farms #5, LTD. 11-30-85 11,896 12,586 167,561
" " 12-31-85 11,896 12,586 167,561
Florin Farms #6, LTD. 11-30-85 11,895 15,753 156,301
" " 12-31-85 11,895 15,753 156,301
Florin Farms #7, LTD. 11-30-85 11,896 604,325 503,400
" " 12-31-85 11,896 604,325 503,400
8936-89 Durham Farms #1, LTD. 11-30-85 11,896 72,790 210,319
" " 12-31-85 11,896 72,790 210,319
Durham Farms #2, LTD. 11-30-85 11,896 71,840 256,102
" " 12-31-85 11,896 71,840 256,102
Durham Farms #3, LTD. 11-30-85 11,896 57,423 217,567
" " 12-31-85 11,896 57,423 217,567
Durham Farms #4, LTD. 11-30-85 11,896 164,953 258,611
" " 12-31-85 11,896 164,953 258,611
Durham Farms #5, LTD. 11-30-85 11,896 324,464 333,433
" " 12-31-85 11,896 324,464 333,433
Durham Farms #6, LTD. 11-30-85 11,896 299,310 374,454
" " 12-31-85 11,896 299,310 374,454
21998-89 Florin Farms #1, LTD. 12-31-83 -0- 41,066 96,375
Florin Farms #2, LTD. 12-31-83 -0- 62,162 94,525
Florin Farms #3, LTD. 12-31-83 -0- 34,722 54,000
Florin Farms #4, LTD. 12-31-83 -0- 50,507 101,275
Florin Farms #5, LTD. 12-31-83 -0- 54,115 94,250
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Florin Farms #6, LTD. 12-31-83 -0- 30,326 87,675
Florin Farms #7, LTD. 12-31-83 -0- 562,528 10,675
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Taxable Adjustments
Year Ordinary Separately Stated
Docket No. Partnership Ending Income Partnership Items
21999-89 Florin Farms #1, LTD. 12-31-84 $ 22,470 $ 94,808
Florin Farms #2, LTD. 12-31-84 46,564 91,981
Florin Farms #3, LTD. 12-31-84 (39,154) 140,692
Florin Farms #4, LTD. 12-31-84 15,831 60,286
Florin Farms #5, LTD. 12-31-84 23,903 77,635
Florin Farms #6, LTD. 12-31-84 15,919 66,991
Florin Farms #7, LTD. 12-31-84 432,052 8,000
22000-89 Durham Farms #1, LTD. 12-31-84 59,778 85,040
Durham Farms #2, LTD. 12-31-84 93,680 136,399
Durham Farms #3, LTD. 12-31-84 63,647 125,996
Durham Farms #4, LTD. 12-31-84 84,268 114,775
22073-89 Durham Farms #1, LTD. 12-31-83 77,738 85,550
Durham Farms #2, LTD. 12-31-83 109,898 126,000
Durham Farms #3, LTD. 12-31-83 85,221 147,900
Durham Farms #4, LTD. 12-31-83 109,583 116,500
26720-89 Washoe Ranches #6, LTD. 12-31-83 83,708 107,350
" " 12-31-84 96,188 123,607
Washoe Ranches #7, LTD. 12-31-83 189,260 26,400
" " 12-31-84 194,713 188,129
27676-89 Washoe Ranches #1, LTD. 12-31-83 118,644 136,775
Washoe Ranches #2, LTD. 12-31-83 89,656 121,325
Washoe Ranches #3, LTD. 12-31-83 78,042 90,000
Washoe Ranches #4, LTD. 12-31-83 87,796 98,650
Washoe Ranches #5, LTD. 12-31-83 121,442 134,800
27722-89 Washoe Ranches #1, LTD. 12-31-84 110,643 192,741
Washoe Ranches #2, LTD. 12-31-84 64,645 128,443
Washoe Ranches #3, LTD. 12-31-84 57,014 81,229
Washoe Ranches #4, LTD. 12-31-84 95,266 117,172
Washoe Ranches #5, LTD. 12-31-84 120,407 162,146
28133-89 Durham Farms #5, LTD. 12-31-83 178,507 15,325
" " 12-31-84 130,863 6,000
Durham Farms #6, LTD. 12-31-83 182,368 6,400
" " 12-31-84 361,380 8,000
6211-90 Durham Farms #1, LTD. 11-30-86 39,084 (105,470)
" " 12-31-86 39,084 (105,470)
Durham Farms #2, LTD. 11-30-86 46,061 (96,471)
" " 12-31-86 46,061 (96,471)
Durham Farms #3, LTD. 11-30-86 35,631 (95,200)
" " 12-31-86 35,631 (95,200)
Durham Farms #4, LTD. 11-30-86 38,509 (101,462)
" " 12-31-86 38,509 (101,462)
Durham Farms #5, LTD. 11-30-86 62,074 (109,353)
" " 12-31-86 62,074 (109,353)
Durham Farms #6, LTD. 11-30-86 136,207 (92,606)
" " 12-31-86 136,207 (92,606)
- 20 -
Taxable Adjustments
Year Ordinary Separately Stated
Docket No. Partnership Ending Income Partnership Items
6262-90 Washoe Ranches #1, LTD. 11-30-86 $66,803 $(129,819)
" " 12-31-86 66,803 (129,819)
Washoe Ranches #2, LTD. 11-30-86 55,302 (86,000)
" " 12-31-86 55,302 (86,000)
Washoe Ranches #3, LTD. 11-30-86 47,599 (80,387)
" " 12-31-86 47,599 (80,387)
Washoe Ranches #4, LTD. 11-30-86 79,117 (128,373)
" " 12-31-86 79,117 (128,373)
Washoe Ranches #5, LTD. 11-30-86 99,665 (142,173)
" " 12-31-86 99,665 (142,173)
Washoe Ranches #6, LTD. 11-30-86 53,692 (101,875)
" " 12-31-86 53,692 (101,875)
Washoe Ranches #7, LTD. 11-30-86 71,240 (133,965)
" " 12-31-86 71,240 (133,965)
7560-90 Florin Farms #1, LTD. 11-30-86 14,491 (65,521)
" " 12-31-86 14,491 (65,521)
Florin Farms #2, LTD. 11-30-86 39,052 (79,058)
" " 12-31-86 39,052 (79,058)
Florin Farms #3, LTD. 11-30-86 1,463 -0-
" " 12-31-86 1,463 -0-
Florin Farms #4, LTD. 11-30-86 (136,597) (190,926)
" " 12-31-86 (136,597) (190,926)
Florin Farms #5, LTD. 11-30-86 17,824 (67,966)
" " 12-31-86 17,824 (67,966)
Florin Farms #6, LTD. 11-30-86 13,139 (54,827)
" " 12-31-86 13,139 (54,827)
Florin Farms #7, LTD. 11-30-86 327,127 (147,715)
" " 12-31-86 327,127 (147,715)