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Engineering 1983-1 (SGE 1983-1), series “A” and “B” units. Above
their signatures, the documents state: “The UNDERSIGNED intends
that their signature hereon shall constitute not only a
subscription but shall also constitute their signature to the
Partnership Agreement”. Below petitioner’s signatures the
documents state: “Signature of Spouse or other Subscriber if
purchase is made jointly”. This was petitioner and Mr. Bartak’s
initial investment in one of the Hoyt partnerships.3
In 1983, petitioner and Mr. Bartak paid no “cash” to SGE
1983-1. In 1984, petitioner and Mr. Bartak paid $17,000 in
“cash” to SGE 1983-1. By 1985, petitioner and Mr. Bartak had
paid at least $31,000 in “cash” to SGE 1983-1.
In late 1984 or early 1985, after petitioner and Mr. Bartak
invested in SGE 1983-1, they went to the Hoyt organization
property (Hoyt ranch). Between 1983 and 1986, petitioner went to
the Hoyt ranch three to four times. After their initial trip to
the Hoyt ranch, petitioner and Mr. Bartak invested in other Hoyt
partnerships including Timeshare Breeding Service #1, Ltd. (TBS
#1). Petitioner and Mr. Bartak signed a subscription agreement
dated February 10, 1985, for TBS #1. Below their signatures, the
line next to “JOINT TENANTS WITH RIGHT OF SURVIVORSHIP” was
marked.
3 Petitioner and Mr. Bartak invested in additional Hoyt
partnerships during and subsequent to the years in issue.
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Last modified: May 25, 2011