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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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