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As of the time of trial, petitioner was 48 years old and in
good health.
Petitioner’s Relationship With Mr. Ellison
Mr. Ellison did not conceal anything from petitioner. Mr.
Ellison did not deceive petitioner. Mr. Ellison did not hide, or
try to hide, any information or documents from petitioner.
Mr. Ellison never threatened or coerced petitioner into
making investments, signing their tax returns, or signing checks.
Mr. Ellison did not abuse petitioner.
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). 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 DGE 1984-2
Around 1985, Mr. Ellison was working in construction. He
heard about the Hoyt partnerships from his co-workers. In the
fall of 1985, he told petitioner about the Hoyt partnerships.
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