Donald J. Barnes and Beverly A. Edwards, f.k.a. Beverly A. Barnes - Page 15

                                       - 15 -                                         
          personal friends of Hoyt family.”  Petitioner stated that her               
          first contact with Hoyt & Sons was through a sales presentation             
          that was attended by herself, Mr. Barnes, and Mr. Hoyt.                     
          Petitioner stated that she and Mr. Barnes were told at this                 
          meeting that “We would be investing in sheep/livestock; buying,             
          raising, selling; and investing in ranch properties and                     
          equipment, feed and grain.”  Petitioner stated that she and Mr.             
          Barnes invested $20,000 in the partnership RCR #4 in 1980, and              
          that the money was provided in the form of a cashier’s check from           
          personal savings and/or from “income tax recapture”.5  Petitioner           
          further stated that she made the investment because:                        
               It sounded like a reasonable investment opportunity;                   
               one that we could follow and participate in locally.                   
               Initially as limited partners, it was considered a                     
               passive partnership.                                                   
          Petitioner stated that she “started out as a limited partner and            
          remained so for 7 or 8 years”, and as of 1995 she was “still an             
          active partner”.  Finally, petitioner stated in the                         
          questionnaire:                                                              
               It really disgusts me that a number of “partnership                    
               dropouts” are engaging in such subversive activities to                
               destroy the Hoyt partnerships.  These people apparently                
               did not understand the partnerships or perhaps had                     
               expectations that exceeded what is real.  The tax                      
               matters have been a horror, mostly because [the] IRS                   
               keeps changing the tax laws and thus attempts to                       

          5The record establishes that the meeting was in 1981 rather                 
          than 1980; that petitioner and Mr. Barnes initially invested in             
          RCR #1; and that they did not invest any cash in the partnership            
          at the time of the initial investment.                                      





Page:  Previous  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  Next

Last modified: May 25, 2011