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each partnership. These herd recap sheets are discussed more
fully infra.
D. Some Investors’ Failure To Make Payments
During the period from 1987 through 1992, a large number of
investors in the cattle-breeding partnerships the Hoyt
organization had formed (including some investors in certain of
the seven cattle-breeding partnerships in the instant cases)
failed to continue making the specified payments required of
them, including paying their pro rata share of the payments
required under their partnership’s “Full Recourse Promissory
Note”. The Hoyt organization never sought to enforce and hold
any of the defaulting investors personally liable for the
payments they had defaulted upon. These investors were allowed
to walk away from their partnership’s “Full Recourse Promissory
Note”.
E. DF #1's, SGE 82-1's, DGE 84-3's, SGE 84-5's, DGE 86-2's, TBS
89-1's, and TBS 90-1's Respective Returns for the Years in Issue
DF #1's returns for some of the years in issue reflect that
it originally claimed depreciation on a “breeding herd” placed in
service in 1990, for which its cost or other basis was
$1,123,972. DF #1 depreciated this breeding herd over 5 years.
SGE 82-1's returns for some of the years in issue reflect
that it originally claimed depreciation on a “breeding herd”
placed in service in 1990, for which its cost or other basis was
$1,923,810. SGE 82-1 depreciated this breeding herd over 12
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