- 3 -
Petitioners resided in Valley Springs, California, when they
filed their petition. Petitioners have been married for 37
years. At the time of trial, petitioner Franklin Hubbart (Mr.
Hubbart) was 66 years old, and petitioner Janetta Hubbart (Mrs.
Hubbart) was 64. Mr. Hubbart retired in 2001, and Mrs. Hubbart
retired in 2000.
In 1984, petitioners became partners in Shorthorn Genetic
Engineering, Ltd. 1984-3 (SGE 84-3), 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 another Hoyt-related
partnership identified as Hoyt and Sons Trucking (HS Truck). The
details of HS Truck 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 84-3 only.
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