- 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 attorneyPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011