- 4 - 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’sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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