Pamela J. Ellison - Page 3

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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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