River City Ranches #1 Ltd., Jeffry Bergamyer, Tax Matters Partner - Page 9
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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.
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Last modified: November 10, 2007