Susan L. Abelein - Page 7

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          Recognize the Partnership has no history of operations or                   
          earnings and this investment therein is a speculative venture,              
          and if they elect to participate, they may lose the total amount            
          of their investment * * *”.                                                 
               DGE issued a Schedule K-1, Partner’s Share of Income,                  
          Credits, Deductions, etc., for 1986 and an amended Schedule K-1             
          for 1985 to petitioner and Mr. Abelein that listed them both as             
          partners.  Petitioner and Mr. Abelein also received Schedules K-1           
          from their other Hoyt investments each year from 1987 to 1995               
          that always listed both petitioner and Mr. Abelein as partners.4            
          Petitioner never questioned why she was listed as a partner or              
          made any effort to remove her name from partnership-related                 
          documents.                                                                  
               After investing in DGE, Mr. Abelein attended partnership               
          meetings at least once a month and asked petitioner to attend               
          with him.  Petitioner attended approximately half of the                    
          meetings.  Petitioner did not ask any questions at the meetings.            
          In 1992 or 1993, petitioner and Mr. Abelein also visited the Hoyt           
          ranches.                                                                    




               4From 1985 through 1996, petitioner and Mr. Abelein invested           
          in several other Hoyt partnerships:  Durham Genetic Engineering             
          1986-A, Florin Farms #4, and Shorthorn Genetic Engineering 1985-            
          1.  The record does not disclose whether the Abeleins invested in           
          these partnerships jointly or separately.                                   





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