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when he filed his petition. Petitioner’s wife, Mary Jane
McDonough, filed separate tax returns for 1989 and 1991.
Petitioner is 57 years old and is currently employed by the Los
Angeles City Fire Department.
Petitioner invested in two partnerships organized and
operated by Walter J. Hoyt III (Hoyt). The partnerships were
Timeshare Breeding Syndicate Joint Venture (TBS) and Timeshare
Breeding Service 1989-1 J.V. (TBS 1989-1).
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 each partnership’s general
partner and tax matters partner. 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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