- 44 - resulting flowthrough partnership deductions were “purchased” with 75 percent of the partner’s tax savings resulting from the flowthrough partnership deductions. The 75-percent tax savings were determined first by computing the partner’s tax liability without participation in a Hoyt partnership and then computing the partner’s tax savings using the Hoyt partnership loss. The difference in the two calculations was the partner’s tax savings, of which 75 percent was paid to the Hoyt organization and 25 percent was to be retained by the partner. In addition, in the initial year of investment, amended returns claiming refunds were often filed for the partner’s prior 3 taxable years. The Hoyt organization received 75 percent of such refunds, and the partners retained 25 percent. Each year the partner’s payment to the Hoyt organization was adjusted to reflect the 75/25 split. Because the investment was based on “tax savings” and not on original cash outlay, Hoyt’s partnership scheme essentially paid for itself. It is clear that the sheep partnerships were merely a facade Hoyt used to provide the fraudulent tax benefits he promised to the partnerships’ investors. Hoyt’s promotional materials so indicate. 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 focusedPage: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 NextLast modified: November 10, 2007