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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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