- 3 - 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 In 1998, Hoyt’s enrolled agent status was revoked.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 andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011