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Sometime before 1985, intervenor was introduced through a
coworker to an investment syndicator and tax preparation service
known to him as Hoyt Investments. Walter J. Hoyt III and some
members of his family were in the business of creating tax
shelter limited partnerships for their cattle breeding
operations. As part of their services, the Hoyt organization
also prepared the investors’ tax returns. For a description of
the Hoyt organization and its operation, see Bales v.
Commissioner, T.C. Memo. 1989-568; see also River City Ranches
#4, J.V. v. Commissioner, T.C. Memo. 1999-209, affd. without
published opinion ___ F.3d ___ (9th Cir., November 26, 2001).
Intervenor attended a meeting organized by the Hoyt
organization at which he decided to participate in a tax shelter
limited partnership and have the Hoyt organization prepare his
and petitioner’s joint Federal income tax returns. Intervenor
signed all the partnership forms, gave the Hoyt organization a
check for $25, and thereby became a limited partner in Shorthorn
Genetic Engineering 1983-2, Ltd. (Shorthorn partnership).
According to the Shorthorn partnership’s records, the partnership
interest was held in the names of both petitioner and intervenor,
even though petitioner had not signed any of the partnership
documents.
Intervenor did not have material discussions with petitioner
about his decision to invest in the Shorthorn partnership tax
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