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and other members of the Hoyt family were extensively involved in
organizing and operating numerous cattle breeding partnerships.
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 until his 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, Hoyt’s enrolled agent status
was revoked.
Hoyt also operated tax return preparation companies,
including “Tax Office of W.J. Hoyt Sons”, “Agri-Tax”, and “Laguna
Tax Service” (Laguna). These companies prepared most of the Hoyt
investors’ tax returns.
B. Petitioner’s Background and Involvement With Hoyt
Petitioner is married and has two stepchildren. Petitioner
has a bachelor of science degree in marine transportation and
management and has been employed by Military Sealift Command
since June 1982.
Before his involvement with Hoyt, petitioner’s only
experience in investing included an investment of $20,000 in the
stock market in 1982 and the purchase of two homes in 1990 and
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