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Petitioners resided in Lodi, California, when they filed
their petition. After filing the petition, but before trial,
Carol Andrews (Mrs. Andrews) passed away from complications
arising after surgery. At the time of her death, Robert Andrews
(Mr. Andrews) and Mrs. Andrews (collectively referred to as
petitioners) had been married for more than 33 years. At the
time of trial, Mr. Andrews was 61 years old.
In 1984, petitioners became partners in Durham Genetic
Engineering 1984-2, Ltd. (DGE 84-2), a cattle breeding
partnership organized and operated by Walter J. Hoyt III (Hoyt).
DGE 84-2 was also known as Timeshare Breeding Service 1984-2,
Ltd. (TBS 84-2). After 1984, petitioners became partners in
Durham Genetic Engineering 1985-4, Ltd. (DGE 85-4), another Hoyt
partnership.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
3(...continued)
evidence, they would have no impact on our findings of fact or on
the outcome of this case.
4 Petitioners were also partners in another Hoyt-related
partnership identified as HS Truck. The details regarding HS
Truck are not in the record. Though unclear, it appears that all
adjustments made to petitioners’ income tax liability for the
years 1981-87 arose from their involvement in DGE 84-2 (or TBS
84-2) and DGE 85-4 only.
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