Gary D. and Johnean F. Hansen - Page 3

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          father’s death in early 1972, Mr. Hoyt and other members of the             
          Hoyt family were extensively involved in organizing and operating           
          numerous cattle breeding partnerships.  From about 1971 through             
          1998, Mr. Hoyt organized, promoted to thousands of investors, and           
          operated as a general partner more than 100 cattle breeding                 
          partnerships.  Mr. Hoyt also organized and operated sheep                   
          breeding partnerships in essentially the same fashion as the                
          cattle breeding partnerships (collectively the “investor                    
          partnerships” or “Hoyt partnerships”).  Each of the investor                
          partnerships was marketed and promoted in the same manner.                  
               Beginning in 1983, and until removed by this Court due to a            
          criminal conviction, Mr. Hoyt was the tax matters partner of each           
          of the investor partnerships that are subject to the provisions             
          of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA),            
          Pub. L. 97-248, 96 Stat. 324.  As the general partner managing              
          each partnership, Mr. Hoyt was responsible for and directed the             
          preparation of the tax returns of each partnership, and he                  
          typically signed and filed each return.  Mr. Hoyt also operated             
          tax return preparation companies, variously called “Tax Office of           
          W.J. Hoyt Sons”, “Agri-Tax”, and “Laguna Tax Service”, that                 
          prepared most of the investors’ individual tax returns during the           
          years of their investments.  Petitioners’ 1991 return was                   
          prepared in this manner and was signed by Mr. Hoyt.  From                   
          approximately 1980 through 1997, Mr. Hoyt was a licensed enrolled           






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