Donald J. Barnes and Beverly A. Edwards, f.k.a. Beverly A. Barnes - Page 14

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               Around the time of petitioner’s divorce in 1986, she was               
          informed that her partnership interest had been transferred from            
          RCR #1 to a similar but separate partnership, River City Ranches            
          #4 (RCR #4).  Around this same time, petitioner personally began            
          making substantial periodic cash payments to RCR #4; these                  
          payments were in addition to the indirect payments that                     
          petitioner was making to RCR #4 in the form of the tax refund               
          checks that were being negotiated on her behalf.  Petitioner                
          continued investing in RCR #4 through at least 1995, and she                
          continued claiming losses with respect to that investment on her            
          income tax returns through that year.                                       
               By letter dated June 9, 1995, petitioner was notified by the           
          Portland, Oregon, office of the Federal Bureau of Investigation             
          (FBI) that the FBI and United States Postal Inspection Service              
          were:                                                                       
               conducting an investigation into allegations that W.J.                 
               Hoyt & Sons and its affiliated entities, and certain                   
               associated individuals, engaged in conduct and/or                      
               practices that may be violations of federal criminal                   
               fraud statutes.                                                        
          Attached to this letter was a questionnaire pertaining to                   
          petitioner’s involvement in “one or more of the W.J. Hoyt & Sons            
          investment programs.”  Petitioner completed portions of this                
          questionnaire.  In answer to the question “How did you first hear           
          of Hoyt & Sons or any of its related entities”, petitioner                  
          responded “Relatives were involved in livestock business and were           






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