- 5 - 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 initialPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011