Eugene A. Sanders - Page 4

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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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