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At the time of trial, petitioner William H. Lindley (Mr. Lindley)
was 58 years old, and petitioner Jo Anne Lindley (Mrs. Lindley)
was 51. Petitioners both have high school educations and have
taken some college classes. Mr. Lindley is a staff manager for
Bell South, and Mrs. Lindley works for the Alabama Policy
Institute.
In 1991, petitioners became partners in Washoe Ranches #3
J.V. (Washoe Ranches) and Timeshare Breeding Services 1989-1 J.V.
(TBS 89-1), partnerships 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 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 Internal Revenue Service (IRS). In
1998, Hoyt’s enrolled agent status was revoked. Hoyt was
convicted of various criminal charges in 2000.3
3 Petitioners ask the Court to take judicial notice of
certain “facts” in other Hoyt-related cases and apply judicial
estoppel to “facts respondent has asserted in previous [Hoyt-
related] litigation”. We shall do neither.
A judicially noticeable fact is one not subject to
(continued...)
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