Verna Doyel - Page 4

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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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