- 9 - 85-2 was formed pursuant to the laws of Nevada. From their inception, all nine sheep partnerships were operated from the Hoyt office in Elk Grove, California. Several of the partnerships did not have signed partnership agreements or had no partnership agreements at all. From the time each Hoyt sheep partnership was formed through 1998, Hoyt was the general partner responsible for all the management, operation, and promotion functions, and he made all major decisions. He was also the TMP of each partnership.7 In the early 1980s, Hoyt had formed so many investor partnerships that the documents, records, and tax returns of the partnerships were inaccurate, unreliable, and in many instances falsified. For the years at issue, often no records were kept. As the general partner managing each sheep partnership, Hoyt was responsible for and directed the preparation of the tax returns of each partnership, and he typically signed and filed each tax return. However, Hoyt did not maintain separate bank accounts or bookkeeping and accounting records for each of the sheep partnerships. From 1981 until sometime in 1990, checks from the sheep partners were deposited in one checking account. 7By orders of the Tax Court issued from June 22, 2000, through May 15, 2001, Hoyt was removed as TMP from the sheep partnerships. Hoyt was also a licensed enrolled agent who represented many of the investor-partners before the IRS. In 1997, the IRS removed Hoyt as an enrolled agent for alleged improprieties relating to his individual income tax returns.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: November 10, 2007