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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.
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