Hoyt and Sons Ranch Properties Ltd. NV - Page 4




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          Hoyt III (Mr. Hoyt).  According to the return, Mr. Hoyt was also            
          the designated TMP for the partnership.  The Burns address and              
          Orovada address were listed on the return as the respective                 
          addresses of the TMP and the tax return preparer.                           
               By letter to respondent, dated June 23, 1998 (Cobb letter),            
          Mr. Cobb requested, as counsel for “all of the Hoyt investor                
          partnerships”:                                                              
               that all notices and correspondence to Mr. Hoyt as Tax                 
               Matters Partner or as a partner in the investor                        
               partnerships, be copied to me as partnerships [sic]                    
               counsel.  If you believe this notice is insufficient                   
               for any reason, I request that you advise me                           
               immediately.                                                           
               Regardless of any reasons which may be advanced for not                
               copying me on partnerships’ notices and correspondence,                
               it is the partnerships’ position that any notice sent                  
               to Mr. Hoyt and not copied to me is insufficient and                   
               that, should any partnership fail to timely respond to                 
               such a notice, that failure is excused by the IRS’s                    
               conduct in failing to copy partnerships’ counsel with                  
               the notice.                                                            
               I have provided to * * * [respondent’s counsel] an                     
               authorization to release information, listing the                      
               partnerships and other entities.                                       
          As mentioned in the above letter, Mr. Cobb submitted an Amended             
          Tax Information Authorization form (authorization form) signed by           
          Mr. Hoyt in his capacity as “Himself, general partner, partner,             
          and/or member of the entities listed on Exhibit 1; and on behalf            
          of any entity listed on Exhibit 2 in which he has the ability to            
          authorize a release.”  Exhibit 1 lists approximately 127                    







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Last modified: May 25, 2011