- 45 - heavily on the investors’ tax savings. One brochure, titled “The 1,000 lb Tax Shelter”, highlighted the investors’ writeoffs, refers to the investment as a tax shelter, and emphasizes that the primary return on an investment in a Hoyt partnership would be from the tax savings. See Van Scoten v. Commissioner, T.C. Memo. 2004-275 (where the Tax Court made a similar finding based on its review of the same Hoyt brochure), affd. 439 F.3d 1243 (10th Cir. 2006). In Van Scoten, we pointed out that the 1,000 lb Tax Shelter brochure spent numerous pages explaining the tax benefits of investing in a Hoyt partnership and explaining why investors should trust only Hoyt’s organization to prepare their individual Federal income tax returns. Another brochure, bearing the heading “Harvesting Tax Savings by Farming the Tax Code”, also emphasized tax savings and explained that the investment could be financed from the investors’ tax savings, which the investors otherwise would have paid to the IRS. The partners’ individual income tax returns were often prepared first by the Hoyt Tax Office to claim partnership deductions or credits sufficient to eliminate or substantially reduce a partner’s tax liability. Subsequently, the partnership returns were prepared to reflect the amounts reported on the partners’ individual income tax returns. The promotional materials explained that, beginning in 1982, other members of the Hoyt Tax Office would sign the individual partners’ tax returnsPage: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 NextLast modified: November 10, 2007