- 6 - Hoyt’s organization prior to investing. Petitioners also did not visit or otherwise investigate the cattle partnership prior to making the investment, although at a later time they visited a sheep ranch that they believed was related to their investment. Petitioners’ initial investment was into a cattle partnership known as Shorthorn Genetic Engineering 86-5 (SGE 86- 5). Petitioners did not make any payment immediately upon signing the investment documents. Rather, the funds for their initial investment were to be derived from the refunds petitioners were to receive upon filing their tax returns. By letter dated October 21, 1987, respondent notified petitioners that the refund that petitioners had requested on their 1986 return had been frozen. The letter stated in relevant part: We have reviewed certain tax deductions and/or credits which are attributable to the above tax shelter promotion [SGE 86-5]. Based upon our review of that promotion, we believe that the tax deductions and/or credits are not allowable. Accordingly, we have reduced the portion of any refund due to you which is attributable to the tax shelter promotion. The examination of the tax shelter promotion will be completed as expeditiously as possible. If the examination results in adjustments to your return, you will be afforded the opportunity to exercise your appeal rights. Prior to preparing petitioners’ next tax return, for 1987, Mr. Hoyt’s organization transferred petitioners’ partnership interest from the SGE 86-5 cattle partnership to a sheep partnership knownPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011