- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011