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Recognize the Partnership has no history of operations or
earnings and this investment therein is a speculative venture,
and if they elect to participate, they may lose the total amount
of their investment * * *”.
DGE issued a Schedule K-1, Partner’s Share of Income,
Credits, Deductions, etc., for 1986 and an amended Schedule K-1
for 1985 to petitioner and Mr. Abelein that listed them both as
partners. Petitioner and Mr. Abelein also received Schedules K-1
from their other Hoyt investments each year from 1987 to 1995
that always listed both petitioner and Mr. Abelein as partners.4
Petitioner never questioned why she was listed as a partner or
made any effort to remove her name from partnership-related
documents.
After investing in DGE, Mr. Abelein attended partnership
meetings at least once a month and asked petitioner to attend
with him. Petitioner attended approximately half of the
meetings. Petitioner did not ask any questions at the meetings.
In 1992 or 1993, petitioner and Mr. Abelein also visited the Hoyt
ranches.
4From 1985 through 1996, petitioner and Mr. Abelein invested
in several other Hoyt partnerships: Durham Genetic Engineering
1986-A, Florin Farms #4, and Shorthorn Genetic Engineering 1985-
1. The record does not disclose whether the Abeleins invested in
these partnerships jointly or separately.
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Last modified: May 25, 2011