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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.
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