- 12 -
$122,000. While the documents signed by petitioner described
above pertain to SGE 86, this document signed by Mr. Hoyt
referred to the partnership known as Shorthorn Genetic
Engineering 1984-2 (SGE 84-2).
In 1989, petitioner received from the Hoyt organization a
copy of this Court’s opinion in Bales v. Commissioner, T.C. Memo.
1989-568. Mr. Hoyt touted the Bales opinion as proof that the
Hoyt partnerships were legal, and that the IRS was incorrect in
challenging their tax claims. Petitioner did not read the entire
opinion, instead relying on information from the Hoyt
organization interpreting the opinion.
Beginning sometime in the early 1990s, petitioner started
attending a number of monthly meetings of Hoyt partners that were
held near petitioner’s home. At these meetings, petitioner would
discuss various issues pertaining to the partnerships with the
other partners, including a number of partners who had visited
the Hoyt ranches. Petitioner considered attendance at these
meetings, as well as any time that he was “actively aware of the
proceedings of the business”, to be material participation with
respect to his investment.
Throughout the years of his involvement with the Hoyt
organization, petitioner’s investment was transferred between
partnerships without any action being taken by petitioner.
Petitioner believed that Mr. Hoyt was using his power of attorney
Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: May 25, 2011