- 8 - 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...)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