- 5 - 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:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008