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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.
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