Bobbie E. Johnson - Page 3

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               Petitioner resided in Lodi, California, when he filed his              
          petition.  At the time of trial, petitioner was 76 years old, his           
          wife (Mrs. Johnson) was 71 years old, and they had been married             
          for more than 50 years.  Petitioner and Mrs. Johnson are retired.           
               In 1984, petitioner became a partner in Durham Genetic                 
          Engineering, Ltd. 1984-4 (DGE 84-4) and Shorthorn Genetic                   
          Engineering, Ltd. 1984-4 (SGE 84-4), cattle breeding partnerships           
          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  Petitioner was also a partner in other Hoyt-related                 
          partnerships identified as TBS 87-1, TBS JV, HS Truck, and TBS              
          1989-3.  The details of these partnerships are not in the record.           
          Though unclear, it appears that all adjustments made to                     
          petitioner’s income tax liability for 1981-86, 1988, and 1992               
          arose from his involvement in DGE 84-4 and SGE 84-4 only.                   





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