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Cattle ranchers use the tax benefits Congress has
given us. Some of us bring the tax benefits to town,
sell them for cash to help pay to produce the beef.
The cows produce beef, and tax benefits for their
owners. Ranchers sell the beef at the store, and the
tax benefits to provide additional capital. The cash
raised from the selling of both items is enough to pay
for the cattle purchase and the operating expenses.
Those that buy the beef get a steak. Those that buy
the tax benefits have the opportunity for ownership in
the cattle herd.
Again, you only considered making an investment in
the cattle business AFTER you heard about the tax
benefits. Tax benefits were your incentive. They
encouraged you to make a high risk business investment.
* * * * * * *
In the country, tax accountants don’t read brands,
and cowboys don’t read tax law. If you must have a tax
man give you specific personal advice as to whether or
not you belong in the cattle business, stay out.
* * * * * * *
A change in the tax laws or an audit and
disallowance by the IRS could take away all or part of
the tax benefits, plus the possibility of having to pay
the tax along with penalties and interest.
Petitioner also received a pamphlet entitled “Registured [sic]
Livestock: The Real ‘Bull Market’ Business Opportunities” (the
business opportunities pamphlet). On its cover, the business
opportunities pamphlet states “HARVESTING TAX SAVINGS BY FARMING
THE TAX CODE”, and it contains much of the same information as
the purchase guide.
On February 14, 1995, petitioner sent to the Hoyt
organization a “Confidential Buyers Information” form, requesting
an “information package”. Dave Barnes (Barnes), a Hoyt employee,
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Last modified: May 25, 2011