Gary D. and Johnean F. Hansen - Page 6

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          II.  Petitioners and Their Investment                                       
               Petitioner wife (Ms. Hansen) is a high school graduate and a           
          licensed respiratory care practitioner.  Petitioner husband (Mr.            
          Hansen) has a college education, with a bachelor of science                 
          degree in civil engineering and architecture.  During the year in           
          issue, Ms. Hansen was employed as a respiratory therapist, and              
          Mr. Hansen was employed as a civil engineer.  At the time they              
          invested in the Hoyt partnerships, petitioners’ investment-                 
          related experience comprised the purchase of their residence, the           
          purchase of a term life insurance policy and Government bonds,              
          the use of savings accounts, and Mr. Hansen’s investments in his            
          employment-related retirement account.  Petitioners did not have            
          any prior experience with farming or cattle.                                
               Petitioners first heard about the Hoyt partnerships from Mr.           
          Hansen’s co-workers in 1986.  At the suggestion of one of these             
          co-workers, who was himself an investor in a Hoyt partnership,              
          petitioners attended an informational session about the                     
          partnerships at the Red Lion Hotel in Pasco, Washington, in the             
          latter part of 1986.  Mr. Hoyt and others involved in the Hoyt              
          organization attended the session, where a presentation was given           
          concerning the nature of the Hoyt partnerships and how they were            
          being marketed as a retirement investment.  While at this                   
          session, petitioners discussed the Hoyt partnerships with                   
          individuals who had already made investments in the partnerships.           






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