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Hoyt partnership he and petitioner would be able to receive a
refund of all the money they paid in taxes for the last 3 years.
Mr. Bartak showed petitioner the Hoyt partnerships
promotional materials, and she read them. Petitioner attended
Hoyt organization meetings and met Mr. Hoyt. From 1983 through
1986, petitioner attended most, if not all, Hoyt organization
meetings that were close to her home. Mr. Bartak asked Mr. Hoyt
questions about the Hoyt partnerships in petitioner’s presence so
that petitioner could learn about the Hoyt partnerships.
Petitioner also asked some questions about the Hoyt partnerships.
Petitioner understood that she and Mr. Bartak would obtain
tax credits and deductions and that there would be large losses
associated with their investment in the Hoyt partnerships.
Petitioner knew that the tax aspects were a big part of the
investment in the Hoyt partnerships.
Petitioner was not interested in investing in the Hoyt
partnerships. Petitioner was skeptical about the Hoyt
partnerships. She did not expect to make a profit even though
Mr. Hoyt said they would. From the very beginning, “something
about it didn’t sit right with” petitioner, and she was never
comfortable with the deductions claimed on her returns associated
with the Hoyt partnerships.
On April 7, 1984, petitioner and Mr. Bartak signed
subscription agreements to invest in Shorthorn Genetic
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Last modified: May 25, 2011