Estate of Carol Andrews, Deceased, Robert Andrews, Special Administrator, and Robert Andrews - Page 3

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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            
               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                

          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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