Susan L. Abelein - Page 9

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          would be “subject to constant audits by the IRS”.  The brochure             
          even warned “If you don’t have a tax man who knows you well                 
          enough to give you specific personal advice as to whether or not            
          you belong in the cattle business, stay out”, and “Don’t have               
          anything to do with any aspect of the cattle business without               
          thorough tax advice”.  The brochure also echoed the language of             
          the subscription agreements, noting:  “If you invest in a cattle            
          partnership, you may lose every last dime you put into it.”                 
               Mr. Abelein occasionally asked petitioner to follow up on              
          the Hoyt information they received.  Mr. Abelein asked petitioner           
          to call the Hoyt organization and to ask questions for him about            
          the materials.  Mr. Abelein also reviewed bills from the Hoyt               
          organization and made payment decisions when necessary, including           
          decisions about additional participation in Hoyt opportunities.             
          Mr. Abelein explained to petitioner what the bills were for and             
          told or asked her to pay them.                                              
               Petitioner wrote numerous checks to the Hoyt organization              
          from her joint account with Mr. Abelein, including a check for              
          $9,770 in 1986.  When the Hoyt bills differed from petitioner’s             
          expectations, she questioned the discrepancies and asked Mr.                
          Abelein to discuss them with the Hoyt organization.  According to           



               5(...continued)                                                        
          any aspect of the cattle business without having a good tax pro             
          working with you all the time as a continuing part of the deal.”            





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