Ingrid Capehart - Page 5

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          Hoyt Partnership Investments                                                
               Walter J. Hoyt III (Mr. Hoyt) was the son of a prominent               
          Shorthorn cattle breeder, who, along with other members of his              
          family, organized, promoted, and operated more than 100 cattle-             
          breeding partnerships (the Hoyt partnerships) from 1971 through             
          1998.  Each partnership was organized and marketed in the same              
          manner, and Mr. Hoyt served as the general partner of each                  
          partnership.  For an overview of the Hoyt organization, 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; Durham Farms #1 v.                       
          Commissioner, T.C. Memo. 2000-159, affd. 59 Fed. Appx. 952 (9th             
          Cir. 2003); River City Ranches #4, J.V. v. Commissioner, T.C.               
          Memo. 1999-209, affd. 23 Fed. Appx. 744 (9th Cir. 2001).                    
               In 1983 Mr. Capehart learned about the Hoyt partnerships               
          from his brother-in-law.  Petitioner and Mr. Capehart eventually            
          met with Mr. Hoyt to discuss the partnerships.  During their                
          initial meeting, Mr. Hoyt explained that he had developed a                 
          special breed of cows, which sold at a very high price, and that            
          their investment in the cattle would grow as the cows reproduced.           
          Mr. Hoyt further explained that he would refile petitioner and              
          Mr. Capehart’s tax returns for the past 3 years and that, in                
          doing so, they would get a refund from the Internal Revenue                 
          Service (IRS), which they could use to make their initial                   






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