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family were extensively involved in organizing and operating
numerous cattle breeding partnerships. From about 1971 through
1998, Jay Hoyt organized, promoted to thousands of investors, and
operated as a general partner more than 100 cattle breeding
partnerships. For convenience, all or some of the cattle
breeding partnerships hereinafter are sometimes referred to as
the Hoyt cattle partnerships or cattle partnerships.5
Before 1971, the Hoyt family for many years resided in
Sacramento, California, and conducted most of their cattle
operations in northern California. In 1975, the family started
relocating their cattle operations to Burns, Oregon, because land
prices became too expensive in northern California. By the
1980s, the Hoyt family resided in the Burns area, and the Hoyt
organization maintained offices in Burns, Oregon, and Elk Grove,
California.
Around 1978 or 1979, Jay Hoyt became interested in the
possibility of organizing sheep breeding partnerships similar to
the cattle breeding partnerships. Due to this interest, Jay Hoyt
began discussions with David Barnes, a longtime sheep breeder and
childhood friend.
David Barnes and his wife April Barnes owned and operated
Barnes Ranch, their sole proprietorship sheep breeding business
5 For a more detailed account of the Hoyt cattle operations
and partnerships see Durham Farms #1, J.V. v. Commissioner, T.C.
Memo. 2000-159, affd. 59 Fed. Appx. 952 (9th Cir. 2003).
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