- 5 - of petitioner’s investment contribution, and the remainder was remitted to Hoyt. A year after petitioner’s initial investment in Timeshares, petitioner’s investment was transferred by Hoyt to Durham Shorthorn Breed Syndicate 1987-C (Durham).6 Petitioner did not sign or receive any partnership documents from Hoyt, such as a subscription agreement, power of attorney, or joint venture partnership agreement, with respect to Durham. Petitioner was not concerned that his investment was transferred by Hoyt to a different partnership.7 At no time during his investment was petitioner aware of the number of cattle owned by Durham. At no time did petitioner request or review Durham’s tax returns or other partnership records. The only financial information petitioner received from Durham was a Schedule K-1, Partner’s Share of Income, Credits, Deductions, Etc., issued for each taxable year 1989, 1990, and 1991. Petitioner had no “idea what the numbers on the [Schedule] K-1 entailed.” 6 Durham is similar to the cattle-breeding partnership at issue in the Court’s opinion in Durham Farms #1, J.V. v. Commissioner, supra. 7 For instance, one of petitioner’s tax returns listed his Hoyt partnership investment as Poison Creek. After an inquiry with Hoyt, petitioner was told that “it doesn’t make any difference. It’s all the same.” Petitioner added that “It was so convoluted that it was hard to figure out what was going on.”Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011