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you were not, somehow, abusing the system, or doing something illegal?”
A section of the “1,000 lb. Tax Shelter” document that was
devoted to a discussion of audits by the IRS stated that the
partnerships would be “branded an ‘abuse’ by the Internal Revenue
Service and will be subject to automatic” and “constant audit”.
Statements in the document compared the IRS to children, stating
that IRS employees did not have the “proper experience and
training” and “working knowledge of concepts required by the
Internal Revenue Code” to evaluate the partnerships. In a
section of the document titled “Tax Aspects”, the following
“warning” was given:
Out here, tax accountants don’t read brands, and our cowboys
don’t read tax law. If you don’t have a tax man who knows
you well enough to give you specific personal advice as to
whether or not you belong in the cattle business, stay out.
The cattle business today cannot be separated from tax law
any more than cattle can be separated from grass and water.
Don’t have anything to do with any aspect of the cattle
business without thorough tax advice, and don’t waste much
time trying to learn tax law from an Offering Circular.
Despite this warning, the document spent numerous pages
explaining the tax benefits of investing in a Hoyt partnership
and explaining why investors should trust only Mr. Hoyt’s
organization to prepare their individual tax returns:
It is the recommendation of the General Partner, as outlined
in the private placement offering circular, that a
prospective Partner seek independent advice and counsel
concerning this investment. * * * The Limited Partners
should then authorize the Tax Office of W.J. Hoyt Sons to
prepare their personal returns. * * * Then you have an
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Last modified: May 25, 2011