- 5 - RCR #4 and RCR #6 each had been formed as a California limited partnership.4 Before 1981, Mr. Hoyt and his family for a number of years had engaged in promoting and operating a number of cattle breeding partnerships. Mr. Hoyt's father was a prominent breeder of Shorthorn cattle, one of the three major breeds of cattle in the United States. In order to expand his business and attract investors, the father had started organizing and promoting cattle breeding partnerships in the late 1960's. One of these cattle breeding partnerships previously was the subject of this Court's opinion in Bales v. Commissioner, T.C. Memo. 1989-568. Around 1978 or 1979, Mr. Hoyt became interested in the possibility of organizing similar sheep breeding partnerships. As a result, he began discussions with David Barnes (Mr. Barnes), a longtime sheep breeder and childhood friend. For a number of years, Mr. Barnes and his wife April had owned and operated Barnes Ranches, their sole proprietorship sheep breeding business located in the Sacramento Valley in California. They have a son, Randy Barnes (Randy). After completing college in 1985, Randy eventually took on a substantial role in the management and operation of the business. 4Although Mr. Hoyt testified that all of the partnerships formed before 1987 had been formed as California limited partnerships, he later indicated that a few of OGT 90's partners may have been limited partners.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011