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(1) During the taxable year 1982, petitioners were partners
in one or more cattle partnerships formed by Walter J. Hoyt, III
(namely, Florin Farms #6);
(2) Petitioner accepted and executed a Sacramento,
California, Appeals Office settlement offer which reads as
follows:
I would like to settle my case on the basis of the
offer first extended by the IRS on January 3, 1992 --
cash out of pocket.
This will be a binding settlement only if you sign a
closing agreement, Form 906, and we countersign it on
behalf of the Commissioner of Internal Revenue. When
we sign the agreement form, the one-year assessment
period of limitations on assessments described at
I.R.C. section 6229(f) will begin.
If you elect to accept the IRS out-of-pocket
settlement offer, please provide the following
information, and return it to us NO LATER THAN JULY 23,
1993.
copies of all cancelled checks written to the Hoyt
organization, or to others acting as agents of the Hoyt
organization (if any);
copies of all annual statements provided to you by the
Hoyt organization;
a schedule which shows a break-down of how the payments
to the Hoyt organization were applied; for example,
-- annual contribution to partnership capital
-- IRA contribution
-- tax preparation fee; and
-- any other amounts you can specifically
identify.
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Last modified: May 25, 2011