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Petitioners resided in Richland, Washington, when they filed
their petition. Petitioners have been married for 46 years.
Petitioner Gordon Freeman (Mr. Freeman) is an electrical
engineer, and petitioner Ilene Freeman (Mrs. Freeman) has a
bachelor of science degree in home economics education. At the
time of trial, Mr. Freeman was 69 years old. Mrs. Freeman’s age
is not in the record.
In 1983, petitioners became partners in Durham Genetic
Engineering, Ltd. 1983-3 (DGE 83-3), 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
Hoyt partners before the Internal Revenue Service (IRS). In
4 Petitioners were also partners in other Hoyt-related
partnerships identified as Timeshare Breeding Services 1987-2
J.V., Timeshare Breeding Syndicate J.V., and Timeshare Breeding
Services 1989-2 J.V. The details of these partnerships are not
in the record. Though unclear, it appears that all adjustments
made to petitioners’ income tax liability for 1980-85 were
attributable to their involvement in DGE 83-3 only, while the
adjustments pertaining to 1989 and 1990 were attributable to the
other partnerships.
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