Susan L. Abelein - Page 4

                                        - 4 -                                         
          inexpensive vacations, and had no investments other than their              
          Hoyt partnership investments and a Hoyt individual retirement               
          account (IRA).                                                              
          Hoyt Partnerships                                                           
               Walter J. Hoyt III (Mr. Hoyt) was the son of a prominent               
          Shorthorn cattle breeder who, along with other members of his               
          family, organized, promoted, and operated more than 100 cattle              
          breeding partnerships from 1971 to 1998.  Each partnership was              
          organized and marketed in the same manner, and Mr. Hoyt served as           
          the general partner of each partnership.  For an overview of the            
          Hoyt organization, see Bales v. Commissioner, T.C. Memo. 1989-              
          568; see also River City Ranches #1, Ltd. v. Commissioner, T.C.             
          Memo. 2003-150; Mekulsia v. Commissioner, T.C. Memo. 2003-138;              
          Durham Farms #1 v. Commissioner, T.C. Memo. 2000-159, affd. 59              
          Fed. Appx. 952 (9th Cir. 2003); River City Ranches #4 v.                    
          Commissioner, T.C. Memo. 1999-209, affd. 23 Fed. Appx. 744 (9th             
          Cir. 2001).                                                                 
          Investment in Durham Genetics Engineering 1985-1 Ltd.                       
               In 1985 Mr. Abelein learned of the Hoyt organization from              
          his brother.  After speaking with another friend who had invested           
          in the Hoyt partnerships, Mr. Abelein contacted an accountant to            
          inquire whether the investment was legal.  Although Mr. Abelein             
          did not pay the accountant or provide the accountant with any of            
          the Hoyt promotional materials, the accountant advised him the              






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011