- 13 - to do the necessary paperwork, and, if asked, petitioner would accept any suggestions made by the Hoyt organization for changes to his investment. Petitioner believed that at least one reason for the changes was to maximize tax savings available to him. Petitioner typically did not receive any type of verification that his partnership interest had been successfully transferred, or that his name had been taken off any promissory notes that had been signed on his behalf. The underlying partnership adjustment in this case was made with respect to a partnership known as Durham Shorthorn Breeding Syndicate 1987-C (DSBS 87-C). There are no documents in the record pertaining to any investment by petitioner in DSBS 87-C. Petitioner made substantial cash payments to the Hoyt organization during the years 1986 through 1997; petitioner estimates that the total amount of these payments was approximately $93,000. These payments included the remittance of his tax refunds, the payment of quarterly and monthly installments on his promissory notes, special “assessments” imposed by the partnerships, and contributions to purported individual retirement account plans maintained by the Hoyt organization. Petitioner has received only nominal amounts of his contributions back from the Hoyt organization. Before and after the year in issue, petitioner received numerous documents purporting to show both the legitimacy of the Hoyt partnershipsPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011