- 3 - conceal anything from petitioner. Mr. Bartak did not deceive or mislead petitioner. Mr. Bartak did not hide, or try to hide, any information or documents from petitioner. Mr. Bartak never threatened or coerced petitioner into making investments, signing their tax returns, or signing checks. Mr. Bartak did not abuse petitioner. Hoyt Partnerships Walter J. Hoyt III and some members of his family were in the business of creating tax shelter limited partnerships for their cattle breeding operations (Hoyt partnerships). As part of their services, the Hoyt organization also prepared the investor’s tax returns. For a description of the Hoyt organization and its operation, see Bales v. Commissioner, T.C. Memo. 1989-568; see also River City Ranches #1 Ltd. v. Commissioner, T.C. Memo. 2003-150; Mekulsia v. Commissioner, T.C. Memo. 2003-138; River City Ranches #4, J.V. v. Commissioner, T.C. Memo. 1999-209, affd. 23 Fed. Appx. 744 (9th Cir. 2001). Investment in SGE 1983-1 and TBS #1 In the early 1980s, Mr. Bartak heard about the Hoyt partnerships from his coworkers. Mr. Bartak met with Mr. Hoyt and reviewed the Hoyt partnerships investment brochures. He understood, and it was explained upfront, that he and petitioner would eventually have to pay taxes on an investment in the Hoyt partnerships. Mr. Bartak was told that when he entered into aPage: 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