Glenn A. Mortensen - Page 13

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          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 partnerships             






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