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FINDINGS OF FACT
We incorporate by reference the findings of fact contained
in River City Ranches I and River City Ranches #4, J.V. v.
Commissioner, T.C. Memo. 1999-209, affd. 23 Fed. Appx. 744 (9th
Cir. 2001).6 Some additional facts have been stipulated, and
they are so found. We incorporate by reference the Twelfth
Stipulation of Facts and the accompanying exhibits.
A. Formation and Operation of the Sheep Partnerships
From about 1971 through 1998, Hoyt organized, promoted to
thousands of investors, and operated as a general partner more
than 100 cattle breeding partnerships. Around 1978 or 1979, Hoyt
became interested in the possibility of organizing sheep breeding
partnerships similar to the cattle breeding partnerships.
Hoyt did not have a separate prospectus for each of the
sheep partnerships. Instead, he used the same promotional
materials he had prepared for the cattle partnerships. And the
promotional materials used to market the investments focused
heavily on the investors’ tax savings. One brochure titled “The
1,000 lb Tax Shelter” highlighted the investors’ writeoffs,
referred to the investment as a tax shelter, and emphasized that
the primary return on an investment in a Hoyt partnership would
6During the original proceedings, the Court took judicial
notice of the facts and record in River City Ranches #4, J.V. v.
Commissioner, T.C. Memo. 1999-209, affd. 23 Fed. Appx. 744 (9th
Cir. 2001).
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Last modified: November 10, 2007