Glenn A. Mortensen - Page 12

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          $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           






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