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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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