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months of imprisonment and ordered to pay restitution to the
victims of his crimes.
B. Criminal Tax Investigations of Jay Hoyt
After the initial IRS examinations of the many cattle
partnerships, several criminal investigations relating to Jay
Hoyt’s activities were commenced by the IRS’s Criminal
Investigation Division (CID).
From April 23, 1984, until April 21, 1986, CID conducted an
investigation of Jay Hoyt for allegedly backdating documents to
enable 12 investor-partners to claim improper deductions and
credits. On April 21, 1986, CID referred the case to IRS
District Counsel, recommending prosecution. On July 31, 1986,
the IRS District Counsel’s Office in Sacramento, California,
referred the matter to the Department of Justice (DOJ) for
prosecution. The DOJ then forwarded the matter to the U.S.
Attorney’s Office in Sacramento for review and consideration. On
August 12, 1987, the U.S. Attorney’s Office declined to prosecute
Jay Hoyt.
On or about July 28, 1989, a member of the IRS Examination
Division team examining Hoyt partnership returns for the 1983
through 1986 taxable years recommended that the CID investigate
Jay Hoyt for allegedly making and/or assisting in fraudulent or
false tax return statements in connection with his promotion and
operation of the cattle partnerships. On October 13, 1989, the
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