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