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Petitioner is married. He has a bachelor of science degree
in marine transportation and management and has been employed by
Military Sealift Command since June 1982.
Petitioner timely filed Federal income tax returns for 1991,
1992, and 1993 and reported the following:
Year Total Income Total Tax Tax Withheld Refund Due
1991 $81,574 $10,662 $16,746 $6,084
1992 70,094 9,035 11,226 2,191
1993 107,841 21,043 22,445 1,402
Respondent assessed the tax as reported and issued the refunds
petitioner claimed.
In 1995, petitioner became a partner in Durham Genetic
Engineering 1990-2 J.V. (DGE), a partnership organized and
operated by Walter J. Hoyt III (Hoyt).
From about 1971 through 1998, Hoyt organized, promoted, and
operated more than 100 cattle breeding partnerships (Hoyt
partnerships). Hoyt also organized, promoted, and operated sheep
breeding partnerships. From 1983 to his subsequent removal by
the Tax Court in 2000 through 2003, Hoyt was the tax matters
partner of each Hoyt partnership. From approximately 1980
through 1997, Hoyt was a licensed enrolled agent, and as such, he
represented many of the Hoyt partners before the IRS. In 1998,
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