Ronald F. and Cynthia G. Van Scoten - Page 9

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          on these promotional materials which, in general, purported to              
          provide rationales for why the partnerships were good investments           
          and why the purported tax savings were legitimate.  One document            
          on which petitioners relied, entitled “Hoyt and Sons -- The 1,000           
          lb. Tax Shelter”, provided information concerning the Hoyt                  
          investment partnerships and how they purportedly would provide              
          profits to investors over time.  The document emphasized that the           
          primary return on an investment in a Hoyt partnership would be              
          from tax savings, but that the U.S. Congress had enacted the tax            
          laws to encourage investment in partnerships such as those                  
          promoted by Mr. Hoyt.  The document stated that an “investment in           
          cattle [is arranged] so the cash required to keep it going is               
          only about seventy five percent” of an investor’s tax savings,              
          while the other twenty-five percent of the tax savings is “a                
          thirty percent return on investment.”  This arrangement                     
          purportedly provided protection to investors:  “If the cows do              
          die and the sky falls in, you have still made a return on the               
          investment, and no matter what happens you are always better off            
          than if you paid taxes.”  After an explanation of the tax                   
          benefits, the document asked:  “Now, can you feel good about not            
          paying taxes, and feeling like you were not, somehow, abusing the           
          system, or doing something illegal?”                                        
               A section of the “1,000 lb. Tax Shelter” document that was             
          devoted to a discussion of audits by the IRS, stated that the               
          partnerships would be “branded an ‘abuse’ by the Internal Revenue           





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