- 5 - Hoyt partnership was legal. Mr. Abelein also contacted a local Internal Revenue Service (IRS) agent to determine whether the investment was legal. The agent would not discuss the Hoyt investment with Mr. Abelein and only answered Mr. Abelein’s general questions regarding the relationship of the Federal Government and the cattle industry. Before investing, petitioner reviewed a Hoyt brochure and had access to other Hoyt materials. Petitioner and Mr. Abelein also attended a Hoyt partnership meeting where two Hoyt representatives were present. Mr. Abelein asked petitioner to go to the meeting because he wanted petitioner to hear about the Hoyt organization directly from those involved in the company rather than from him. Mr. Abelein was very forthcoming towards petitioner with respect to what he knew about the Hoyt partnerships. He explained to petitioner that they would claim losses from the partnership on their joint tax returns and should not expect to earn a profit until the 8th to 10th year of the partnership. Petitioner knew that she and Mr. Abelein could get refunds from previous years’ tax returns and invest them in the Hoyt cattle business. Petitioner and Mr. Abelein agreed that they should invest in the Hoyt organization to help pay for their children’s college tuition.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