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Hoyt family were extensively involved in organizing and operating
numerous cattle breeding partnerships. From about 1971 through
1998, Mr. Hoyt organized, promoted to thousands of investors, and
operated as a general partner more than 100 cattle breeding
partnerships. Mr. Hoyt also organized and operated sheep
breeding partnerships in essentially the same fashion as the
cattle breeding partnerships (collectively the investor
partnerships or Hoyt partnerships). Each of the investor
partnerships was marketed and promoted in the same manner.
Beginning in 1983, and until removed by this Court due to a
criminal conviction, Mr. Hoyt was the tax matters partner of each
of the investor partnerships that are subject to the provisions
of the Tax Equity & Fiscal Responsibility Act of 1982, Pub. L.
97-248, 96 Stat. 324. As the general partner managing each
partnership, Mr. Hoyt was responsible for and directed the
preparation of the tax returns of each partnership, and he
typically signed and filed each return. Mr. Hoyt also operated
tax return preparation companies, variously called “Tax Office of
W.J. Hoyt Sons”, “Agri-Tax”, and “Laguna Tax Service”, that
prepared most of the investors’ individual tax returns during the
years of their investments. Petitioners’ 1991 return was
prepared in this manner and was signed by Mr. Hoyt. From
approximately 1980 through 1997, Mr. Hoyt was a licensed enrolled
agent, and as such he represented many of the investor-partners
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