Susan L. Abelein - Page 8

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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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