Daniel O. Abelein - Page 3

                                        - 3 -                                         
               Petitioner resided in Boring, Oregon, when he filed his                
          petition.  Petitioner has a highschool education, worked as an              
          electrician for many years, and is now self-employed as a general           
          contractor building houses in the Greater Portland, Oregon, area.           
          At the time of trial, petitioner was 55 years old.                          
               In 1985, petitioner became a partner in Durham Genetic                 
          Engineering, Ltd. 1985-1 (DGE 85-1) and in Shorthorn Genetic                
          Engineering, Ltd. 1985-1 (SGE 85-1), cattle breeding partnerships           
          organized and operated by Walter J. Hoyt III (Hoyt).4                       
               From about 1971 through 1998, Hoyt organized, promoted, and            
          operated more than 100 cattle breeding partnerships.  Hoyt also             
          organized, promoted, and operated sheep breeding partnerships.              
          From 1983 to his subsequent removal by the Tax Court in 2000                
          through 2003, Hoyt was the tax matters partner of each Hoyt                 
          partnership.  From approximately 1980 through 1997, Hoyt was a              
          licensed enrolled agent, and as such, he represented many of the            
          Hoyt partners before the Internal Revenue Service (IRS).  In                



               4  The parties stipulated that petitioner became a partner             
          in DGE 85-1 and SGE 85-1 in 1984.  However, petitioner testified,           
          and the rest of the record indicates, that he became a partner in           
          1985.                                                                       
               Petitioner was also a partner in other Hoyt-related                    
          partnerships identified as “DGE 1986-A” and “FF #4”.  The details           
          of these partnerships are not in the record. Though unclear, it             
          appears that all adjustments made to petitioner’s income tax                
          liability for 1982-86 were attributable to his involvement in DGE           
          85-1 and SGE 85-1 only.                                                     





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