- 6 - and equipment typically associated with ranches. Petitioner did not see (or ask to see) any record pertaining to a Hoyt partnership. On July 15, 1988, petitioner signed a four-page document memorializing his intent to buy two units in TBS at a total cost of $7,000. The document (TBS document) included sections entitled “SUBSCRIPTION AGREEMENT AND SIGNATURE PAGE”, “CERTIFICATION”, “POWER OF ATTORNEY”, “FILING ACKNOWLEDGEMENT”, and “PARTNERSHIP AGREEMENT”, and it referenced a section in the partnership agreement entitled “Risk Factors”. The document stated that petitioner, as a signer of the document, “recognizes that even though the Partnership has a four year history of operations and earnings, their [his] investment therein is a speculative venture, and if they elect [he elects] to participate, they [he] may lose the total amount of their [his] investment.” Petitioner did not seek independent professional advice as to the TBS document before signing it, opting instead to rely upon the words and actions of his coworkers as to their participation in one or more Hoyt partnerships. Later, petitioner purchased interests in DSBS 87-C and TBS 89-1, without signing any partnership document as to those purchases. Petitioner knew at the time of his purchases that the Hoyt partnerships advertised that his participation in a Hoyt partnership allowed him to claim refunds of Federal income tax,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007