- 5 -
States. In order to expand his business and attract investors,
Mr. Hoyt’s father had started organizing and promoting cattle
breeding partnerships by the late 1960s. Before and after his
father’s death in early 1972, Mr. Hoyt and other members of the
Hoyt family were extensively involved in organizing and operating
numerous cattle breeding partnerships. From about 1971 through
1998, Mr. Hoyt organized, promoted to thousands of investors, and
operated as a general partner more than 100 cattle breeding
partnerships. Mr. Hoyt also organized and operated sheep
breeding partnerships in essentially the same fashion as the
cattle breeding partnerships (collectively the “investor
partnerships”). Each of the investor partnerships was marketed
and promoted in the same manner.
Beginning in 1983, and until removed by this Court due to a
criminal conviction, Mr. Hoyt was the tax matters partner of each
of the investor partnerships that are subject to the provisions
of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA),
Pub. L. 97-248, 96 Stat. 324. As the general partner managing
each partnership, Mr. Hoyt was responsible for and directed the
preparation of the tax returns of each partnership, and he
typically signed and filed each return. Mr. Hoyt also operated
tax return preparation companies, variously called “Tax Office of
W.J. Hoyt Sons”, “Agri-Tax”, and “Laguna Tax Service”, that
prepared most of the investors’ individual tax returns during the
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