Robert and Grace Bergevin - Page 5




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          The criminal charges included fraud, mail fraud, bankruptcy                 
          fraud, and money laundering.  The essence of the criminal charges           
          was that Hoyt had victimized approximately 4,000 investors,                 
          including petitioners.                                                      
          Petitioners                                                                 
               On their income tax returns beginning in 1984, petitioners             
          claimed losses and credits from their involvement in a cattle               
          investor partnership organized and operated by Hoyt and                     
          identified as Shorthorn Genetic Engineering 1984-4 Ltd.                     
          Petitioners also claimed that losses related to the Hoyt                    
          partnership carried back to 1981, 1982, and 1983.  Additional               
          deductions were claimed on petitioners’ returns for 1985 and                
          1986.  As a result of delays caused by Hoyt’s dealings with the             
          IRS and the various investigations of Hoyt, the taxes for the               
          years in issue were not assessed until sometime in 1998.                    
          Section 6330 Proceedings                                                    
               On March 21, 2005, the IRS sent to each petitioner a                   
          separate Final Notice–-Notice Of Intent To Levy And Notice Of               
          Your Right To A Hearing for each of the years 1981, 1982, 1983,             
          1984, and 1986.  A Request for a Collection Due Process Hearing             
          was filed on behalf of petitioners on or about April 7, 2005.               
               Petitioners’ request for a section 6330 hearing included the           
          following arguments:                                                        
               Mr. and Mrs. Bergevin believe that the Notice of Intent                
               to Levy is improper for the following reasons:                         






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