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T.C. Memo. 1989-568.4 Petitioner also recalled seeing the
articles “The 1,000 lbs. Tax Shelter” and “Harvesting the Tax
Code” among the Hoyt promotional materials. Petitioner did not
consult an attorney or a tax professional with respect to the
information provided in the Hoyt promotional materials.
In November 1989, petitioner invested in the Hoyt
partnerships. Petitioner did not consult an attorney or a tax
professional at any time before making his Hoyt investment.
Petitioner originally invested in Hoyt’s Timeshares Breeding
Services (Timeshares) partnership.5 Petitioner signed and
executed a Joint Venture Partnership Agreement for five units at
a total price of $17,500. Petitioner also executed, among other
documents, a Power of Attorney and a Certificate Of Assumption Of
Primary Liability. Petitioner did not have an attorney review
these documents. Petitioner believed that his Hoyt investment
was an “undivided share of a herd.” At the time of his
investment, petitioner provided a check in the amount of $17,500
to Mr. Parker for “5 bull units”. Mr. Parker retained a portion
4 At that time, petitioner was aware that the Bales opinion
applied only to the 1977 through 1979 taxable years.
5 Timeshares was started by the Hoyt organization in the
mid-1980s. In general, Timeshares arranged leases of bulls
ostensibly owned by the Timeshares cattle-breeding partnerships
the Hoyt family had organized and promoted to numerous investors.
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