- 5 -
2. Hoyt and His Organization
From about 1971 through 1998, Hoyt organized, promoted, and
operated as a general partner various cattle breeding
partnerships. Three of the partnerships were Durham Shorthorn
Breed Syndicate 1987-C J.V. (DSBS 87-C), Timeshare Breeding
Service J.V. (TBS), and TBS 89-1. Hoyt organized, marketed,
promoted, and operated all of his partnerships in essentially the
same fashion. Among other things, Hoyt was responsible for and
directed the preparation of each partnership’s tax returns, and
he typically signed and filed each of those returns.
3. Petitioner’s Involvement With the Hoyt Partnerships
In or about 1986, petitioner heard about the Hoyt
partnerships from his fellow firefighters at the LAFD.
Petitioner knew that 12 of his close coworkers either were
considering participating in a Hoyt partnership or had
participated in a Hoyt partnership. Petitioner knew that two of
those coworkers had participated in one or more of the Hoyt
partnerships for as long as 10 years.
In 1988, petitioner decided to participate in some of the
Hoyt partnerships with an intent to acquire a tax shelter and to
generate funds for his retirement. Previously, in 1987 or 1988,
petitioner had visited Hoyt’s main office in Elk Grove,
California, and he had toured Hoyt’s facilities and ranches in
Burns, Oregon. During his visit and tour, petitioner saw land
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: November 10, 2007