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The Abeleins’ Treatment of Hoyt Documents
The Abeleins received correspondence from the Hoyt
organization, including monthly newsletters, advertisements, and
newspaper articles which informed them of recent developments in
the cattle breeding industry and events taking place within the
Hoyt organization. Mr. Abelein would typically read the
correspondence and then leave it for petitioner to read or file
with their other Hoyt-related materials. Petitioner looked at
the pictures and read the social news in the correspondence but
chose not to read the materials that were business-related or
contained a lot of words. Petitioner had access to the
correspondence at all times.
In addition, the Abeleins received a brochure entitled “The
1,000 lb. Tax Shelter, A ROUND-UP OF DATA AND A QUICK COURSE IN
CATTLE BREEDING TAX SHELTERS” from the Hoyt organization. The
“Specific Risks Involved” section of the brochure stated: “A
change in the tax law or an audit and disallowance by the IRS
could take away all or part of the tax benefits, plus the
possibility of having to pay back the tax savings, with penalties
and interest.”5 The brochure highlighted that the partnerships
5This same language was used in the “Registered Livestock
Purchase Guide”, another Hoyt brochure petitioner received. This
brochure also compared investing in a Hoyt partnership to a
roller coaster ride and cautioned: “The cattle business today
cannot be separated from tax law any more than cattle can be
separated from grass and water. Don’t have anything to do with
(continued...)
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