- 9 - 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 RevenuePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011