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Petitioners resided in Corbett, Oregon, when they filed
their petition. Petitioners have been married for 33 years, have
two adult children, and one grandchild. At the time of trial,
petitioner Roger Carter (Mr. Carter) was 55 years old and
petitioner Lora Carter (Mrs. Carter) was 53. Mr. Carter has a
high school education and is currently employed as a supervising
electrician. Mrs. Carter has a degree as a dental assistant, but
has worked only sporadically since 1974. At the time of
petitioners’ section 6330 hearing, Mrs. Carter worked at Lowe’s,
a home improvement store.
In 1984, petitioners became partners in Shorthorn Genetic
Engineering, Ltd. 1984-4 (SGE 84-4), a cattle breeding
partnership 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
4 Petitioners were also partners in other Hoyt-related
partnerships identified as DSBS 1990-5, HS Truck, TBS 1989-3, and
TBS. The details of these partnerships are not in the record.
Though unclear, it appears that all adjustments made to
petitioners’ income tax liability for the years in issue arose
from their involvement in SGE 84-4 only.
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