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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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Last modified: May 25, 2011