Susan L. Abelein - Page 5

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          Hoyt partnership was legal.  Mr. Abelein also contacted a local             
          Internal Revenue Service (IRS) agent to determine whether the               
          investment was legal.  The agent would not discuss the Hoyt                 
          investment with Mr. Abelein and only answered Mr. Abelein’s                 
          general questions regarding the relationship of the Federal                 
          Government and the cattle industry.                                         
               Before investing, petitioner reviewed a Hoyt brochure and              
          had access to other Hoyt materials.  Petitioner and Mr. Abelein             
          also attended a Hoyt partnership meeting where two Hoyt                     
          representatives were present.  Mr. Abelein asked petitioner to go           
          to the meeting because he wanted petitioner to hear about the               
          Hoyt organization directly from those involved in the company               
          rather than from him.                                                       
               Mr. Abelein was very forthcoming towards petitioner with               
          respect to what he knew about the Hoyt partnerships.  He                    
          explained to petitioner that they would claim losses from the               
          partnership on their joint tax returns and should not expect to             
          earn a profit until the 8th to 10th year of the partnership.                
          Petitioner knew that she and Mr. Abelein could get refunds from             
          previous years’ tax returns and invest them in the Hoyt cattle              
          business.  Petitioner and Mr. Abelein agreed that they should               
          invest in the Hoyt organization to help pay for their children’s            
          college tuition.                                                            








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