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Glenn and Petitioner’s Glenn and Petitioner’s
Reported AGI Before Reported AGI After
Hoyt Partnership-Related Hoyt Partnership-Related
Year Claimed Tax Benefits Claimed Tax Benefits
1987 $51,210 0
1988 46,696 0
1989 51,435 0
1990 64,522 ($142,216)
1991 61,669 5,030
1992 69,530 29,639
1993 68,124 25,882
1994 86,523 76,368
When a tax refund was received, it was deposited by Glenn
into one of Glenn’s separate bank accounts, and Glenn would then,
pursuant to his commitment under the Hoyt partnership agreement,
write a check on one of his separate bank accounts to either a
Hoyt partnership or a Hoyt partnership-related entity for a
nearly identical amount.
Attached to the 1991, 1992, and 1993 joint Federal income
tax returns were material participation statements indicating
that Glenn and petitioner were co-owners of a cattle production
and sales business. Attached to the 1992 return was an affidavit
signed by Glenn and petitioner, stating that Glenn and petitioner
were “actively engaged” in the business of cattle ranching.
Petitioner, however, was not in any way involved in the
preparation of the above joint Federal income tax returns. Glenn
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