- 13 -
Petitioners were involved in a variety of different cattle
breeding partnerships from 1987 through 1996, including Shorthorn
Genetic Engineering 1986-B, Hoyt and Sons Trucking, Timeshare
Breeding Services, and Timeshare Breeding Services 1989-1.
During the year in issue, petitioners were involved with the
partnerships known as Durham Shorthorn Breed Syndicate 1987-A,
J.V. (DSBS 87-A) and Durham Shorthorn Breed Syndicate 1987-C,
J.V. (DSBS 87-C). Ms. Hansen believed that the Hoyt
organization’s frequent changing of their partnership investments
was the result of tax law changes rather than problems with the
underlying business operations.
Although petitioners did not personally visit or otherwise
independently investigate the cattle ranching operations prior to
their investment, in 1990 and again in 1993 petitioners
participated in “ranch tours”. These tours were annual events
where partners met one another, toured Hoyt-related ranches, and
talked with people involved in the Hoyt organization. When
visiting the ranches, Ms. Hansen did not know which cattle
belonged to any given partnership, or whether the herds were
segregated in any manner. Beginning sometime in either 1989 or
the early 1990s, petitioners also attended a number of monthly
meetings of Hoyt partners that were held near petitioners’ home.
Various guest speakers were invited to these meetings, and
members of the Hoyt organization would also attend on occasion.
Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: May 25, 2011