- 12 - 1995, the joint returns and the separate returns filed by petitioner were prepared by Mr. Hoyt or one of his tax services. In 1981, petitioner and Mr. Barnes met with Mr. Hoyt concerning a possible investment in a Hoyt investor partnership. Mr. Barnes had known Mr. Hoyt for many years prior to the time that petitioner and Mr. Barnes made their investment in 1981, and Mr. Barnes knew that Mr. Hoyt had been involved in cattle ranching. Prior to her meeting with Mr. Hoyt, petitioner believed that David Barnes was interested in raising sheep and that he was interested in expanding what essentially was his hobby into a commercial sheep ranching operation. Petitioner believed that David Barnes was working with Mr. Hoyt in developing a business related to sheep ranching, and petitioner knew that David Barnes wanted petitioner and Mr. Barnes to speak with Mr. Hoyt about this business. As a result of the 1981 meeting, petitioner and Mr. Barnes made the decision to invest in one of the sheep partnerships organized and promoted by Mr. Hoyt, namely RCR #1. Petitioner and Mr. Barnes did not invest any cash at the time they initially decided to make the investment. Instead, the invested funds were obtained using the tax refunds that Mr. Hoyt helped secure by preparing tax forms for petitioner and Mr. Barnes. Petitioner and Mr. Barnes agreed that Mr. Hoyt would retain 75 percent of the tax refunds that they were to receive, and that petitioner and Mr. Barnes would receive thePage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011