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