- 5 - 1985, petitioner and Mr. Ellison invested in Durham Genetic Engineering 1984-2 (DGE 1984-2), one of the Hoyt partnerships.3 In 1985, petitioner and Mr. Ellison paid no “cash” to DGE 1984-2. In 1986, petitioner and Mr. Ellison paid $20,750 in “cash” to DGE 1984-2. Petitioner signed checks, on accounts held jointly by petitioner and Mr. Ellison, made payable to Hoyt partnerships or the Hoyt organization. Several of these checks were for thousands of dollars. Petitioner did not ask Mr. Ellison detailed questions about the Hoyt partnerships--especially before they were contacted by the Internal Revenue Service (IRS) about this investment and the deductions associated with it. Mr. Ellison’s responses to petitioner’s questions usually were along the lines of: “Hoyt has it under control”, “Hoyt is dealing with it”, or “Don’t worry about it”. Apart from the Hoyt partnerships, petitioner and Mr. Ellison did not have any investments at the time they invested in the Hoyt partnerships. Documents From the Hoyt Organization Promotional materials and correspondence, including bills, from the Hoyt organization were mailed (i.e., addressed) to 3 Petitioner and Mr. Ellison invested in several other Hoyt partnerships subsequent to the years in issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011