- 11 - 89-1. The $1,800 may or may not have been related to petitioner’s participation in TBS 89-1. For 1988, 1989, 1990, and 1991, petitioner received Federal income tax refunds as follows: Year Refund Amount Date Refund Issued 1988 $10,714 May 29, 1989 1989 1,423 July 9, 1990 1990 3,850 July 29, 1991 1991 4,053 Nov. 2, 1992 5. Documents From the Internal Revenue Service Before signing his 1991 tax return, petitioner received notices of beginning of administrative proceeding (NBAP) informing him that the Commissioner was examining the 1988, 1989, and 1990 taxable years of DSBS 87-C. Petitioner never took any of the NBAPs to a tax professional independent of the Hoyt organization, e.g., to inquire about its significance. Before signing his 1991 tax return, petitioner also received two letters from the Internal Revenue Service, containing information regarding material participation and section 469. 6. The Bales Memorandum Opinion The case of Bales v. Commissioner, T.C. Memo. 1989-568, pertained to Hoyt cattle partnerships (not including TBS 89-1) and their 1974 through 1981 taxable years. The Court in Bales decided that those partnerships were not shams. After Bales was decided, Hoyt promoted the Hoyt partnerships to prospective participants by referring to the case.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 NextLast modified: November 10, 2007