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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.”
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