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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.
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Last modified: May 25, 2011