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significant investment experience, and he did not have any
experience with farming or cattle.
Petitioner first learned about the Hoyt partnerships from a
coworker in late 1985 or early 1986. At the suggestion of this
coworker, who was already an investor in a Hoyt partnership,
petitioner decided to look into making an investment.
Petitioner, along with a group of four or five other coworkers,
acquired an informational packet from the Hoyt organization.
Petitioner first invested in the Hoyt partnerships in 1986.
Prior to investing, petitioner received promotional materials
prepared by the Hoyt organization, some of which he had acquired
in his initial request for information. Petitioner relied on
these promotional materials which, in general, provided
rationales for why the partnerships were good investments and why
the purported tax savings were legitimate. One document on which
petitioner relied, entitled “Hoyt and Sons -- The 1,000 lb. Tax
Shelter”, provided information concerning the Hoyt investment
partnerships and how they purportedly would provide profits to
investors over time. The document emphasized that the primary
return on an investment in a Hoyt partnership would be from tax
savings, but that the U.S. Congress had enacted the tax laws to
encourage investment in partnerships such as those promoted by
Mr. Hoyt. The document stated that an “investment in cattle [is
arranged] so the cash required to keep it going is only about
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