Ann E. Bartak - Page 3

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          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 a              






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