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Investments
Christopher researched the investments petitioner and
Christopher made. Christopher then talked with petitioner about
what he learned, and petitioner and Christopher reached an
agreement on whether or not to invest in that particular
investment. Petitioner and Christopher had an agreement to reach
a consensus about investment decisions. Neither did anything
without talking it over with the other.
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 or Hoyt
investments). 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 1984-2
Christopher first heard about the Hoyt partnerships in 1983
from a coworker. In 1984, Christopher and petitioner’s
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