Patricia M. Mora, F.K.A. Patricia Rasberry - Page 4




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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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