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Service and will be subject to automatic” and “constant audit”.
Statements in the document compared the IRS to children, stating
that IRS employees did not have the “proper experience and
training” and “working knowledge of concepts required by the
Internal Revenue Code” to evaluate the partnerships. In a
section of the document titled “Tax Aspects”, the following
“warning” was given:
Out here, tax accountants don’t read brands, and our cowboys
don’t read tax law. If you don’t have a tax man who knows
you well enough to give you specific personal advice as to
whether or not you belong in the cattle business, stay out.
The cattle business today cannot be separated from tax law
any more than cattle can be separated from grass and water.
Don’t have anything to do with any aspect of the cattle
business without thorough tax advice, and don’t waste much
time trying to learn tax law from an Offering Circular.
Despite this warning, the document spent numerous pages
explaining the tax benefits of investing in a Hoyt partnership,
and explaining why investors should trust only Mr. Hoyt’s
organization to prepare their individual tax returns:
It is the recommendation of the General Partner, as outlined
in the private placement offering circular, that a
prospective Partner seek independent advice and counsel
concerning this investment. * * * The Limited Partners
should then authorize the Tax Office of W.J. Hoyt Sons to
prepare their personal returns. * * * Then you have an
affiliate of the Partnership preparing all personal and
Partnership returns and controlling all audit activity with
the Internal Revenue Service. * * * Then, all Partners are
able to benefit from the concept of “Circle the Wagons,” and
no individual Partner can be isolated and have his tax
losses disallowed because of the incompetence or lack of
knowledge of a tax preparer who is not familiar with the
law, regulations, format, procedures, and operations
concerning the Partnership that are required to protect the
Limited Partners from Internal Revenue audits. * * * If a
Partner needs more or less Partnership loss any year, it is
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Last modified: May 25, 2011