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After approximately 1980, the IRS regularly examined many of
the partnership returns of the numerous Hoyt investor
partnerships and the individual returns of their partners.
Believing the partnerships to be abusive tax shelters, the IRS
generally disallowed the partnership tax benefits that each
investor partnership and its respective partners claimed,
resulting in those partnerships’ and partners’ commencing
numerous cases in the Tax Court.
The Hoyt organization is no stranger to this Court. Since
1989, the Hoyt organization’s investor partnerships have been
involved in Tax Court litigation for tax years from 1977 through
1996. See Durham Farms #1, J.V. v. Commissioner, T.C. Memo.
2000-159, affd. 59 Fed. Appx. 952 (9th Cir. 2003); River City
Ranches #4, J.V. v. Commissioner, T.C. Memo. 1999-209, affd. 23
Fed. Appx. 744 (9th Cir. 2001); Shorthorn Genetic Engg. 1982-2,
Ltd. v. Commissioner, T.C. Memo. 1996-515; Bales v. Commissioner,
T.C. Memo. 1989-568.
On February 12, 2001, Jay Hoyt was convicted in the U.S.
District Court for the District of Oregon of 1 count of
conspiracy to commit fraud, 31 counts of mail fraud, 3 counts of
bankruptcy fraud, and 17 counts of money laundering. See United
States v. Barnes, No. CR 98-529-JO-04 (D. Or. Feb. 12, 2001),
affd. 47 Fed. Appx. 834 (9th Cir. 2002). He was sentenced to 235
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