Gary D. and Johnean F. Hansen - Page 16

                                       - 16 -                                         
               1987     1988     1989     1990                                        
               Income1              $65,750  $59,281  $61,239  $63,388                
               Partnership losses     142,950   28,972   37,249   41,470              
               Tax liability              -0-    2,344    1,902    1,466              
                    1Includes taxable income from wages, interest, and                
               dividends.                                                             
          The Form 1045 and each of the returns from 1987 through 1990 were           
          prepared by an individual affiliated with the Hoyt organization.            
               By letter dated April 25, 1989, respondent notified                    
          petitioners that one of their Hoyt partnerships was under review.           
          This letter stated in relevant part:                                        
               Our information indicates that you were a partner in the               
               above partnership [DSBS 87-C] during the above tax year                
               [1988].  Based upon our review of the partnership’s tax                
               shelter activities, we have apprised the Tax Matters Partner           
               that we believe the purported tax shelter deductions and/or            
               credits are not allowable and, if claimed, we plan to                  
               examine the return and disallow the deductions and/or                  
               credits.  The Internal Revenue Code provides, in appropriate           
               cases, for the application [of various penalties].                     
          In January 1992, respondent mailed Hoyt investors, including                
          petitioners, a letter regarding the application of section 469              
          (relating to passive activity loss limitations).  That same                 
          month, Mr. Hoyt mailed a letter to investors, including                     
          petitioners, setting forth arguments that Hoyt investors                    
          materially participated in their investments within the meaning             
          of section 469.  In this letter, Mr. Hoyt stated that                       
          respondent’s assertions in the preceding letter were incorrect,             
          and that the investors should do what was necessary to                      
          participate in their investment at least 100 or 500 hours per               





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