- 3 - Petitioner resided in Boring, Oregon, when he filed his petition. Petitioner has a highschool education, worked as an electrician for many years, and is now self-employed as a general contractor building houses in the Greater Portland, Oregon, area. At the time of trial, petitioner was 55 years old. In 1985, petitioner became a partner in Durham Genetic Engineering, Ltd. 1985-1 (DGE 85-1) and in Shorthorn Genetic Engineering, Ltd. 1985-1 (SGE 85-1), cattle breeding partnerships organized and operated by Walter J. Hoyt III (Hoyt).4 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 4 The parties stipulated that petitioner became a partner in DGE 85-1 and SGE 85-1 in 1984. However, petitioner testified, and the rest of the record indicates, that he became a partner in 1985. Petitioner was also a partner in other Hoyt-related partnerships identified as “DGE 1986-A” and “FF #4”. The details of these partnerships are not in the record. Though unclear, it appears that all adjustments made to petitioner’s income tax liability for 1982-86 were attributable to his involvement in DGE 85-1 and SGE 85-1 only.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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