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section 6621(c)(3)(A)(i), or (b) “sham and fraudulent
transaction” as defined in section 6621(c)(3)(A)(v).
FINDINGS OF FACT
Some of the facts and certain documents have been stipulated
for trial pursuant to Rule 91 and are found accordingly. The
Court incorporates the parties’ stipulations in this opinion by
reference.
The parties have stipulated that at the time the respective
petitions herein were filed, each of the nine Hoyt sheep
partnerships maintained its principal place of business in Burns,
Oregon. However, the record reflects that the partnerships were
operated from a Hoyt organization office located in Elk Grove,
California. Further, each sheep partnership, with the exception
of River City Ranches 85-2, was formed under and governed by
California law. River City Ranches 85-2 was a Nevada general
partnership and in 1991 became known as River City Ranches #7
(RCR #7).
A. Overview of the Hoyt Operations
Jay 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 by the late 1960s. Before and after the father’s
death in early 1972, Jay Hoyt and other members of the Hoyt
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