- 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 landPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007