- 7 -
On at least four separate occasions, from April 1984 through
September 1995, Jay Hoyt was under criminal investigation for
violation of the internal revenue laws. Respondent never
notified Jay Hoyt that he was under criminal investigation or
removed him as the TMP of Shorthorn Genetic Engineering 1985-1
(SGE) as a result of any of these criminal tax investigations.
C. Petitioner’s Involvement With the Hoyt Organization
Starting in 1985, petitioner began investing in cattle
partnerships promoted by the Hoyt organization. According to the
petition filed in this case, petitioner was a partner in SGE,
Timeshare Breeding Syndicate, J.V., and Timeshare Breeding
Syndicate 1987-2. As the interest of which he seeks abatement in
this case accrued on assessments of income tax against petitioner
for tax years 1982 through 1987, solely on the basis of his
participation in SGE during 1985 and 1986, our analysis is
limited to the tax implications of petitioner’s association with
the SGE partnership only.
Petitioner was a partner in SGE from 1985 through 1996. SGE
was a partnership subject to the provisions of sections 6221
through 6233.5 On SGE’s 1985 and 1986 partnership tax returns,
Jay Hoyt was designated the TMP.
5 The unified partnership audit and litigation provisions
of secs. 6221-6223 were first enacted as part of the Tax Equity
and Fiscal Responsibility Act of 1982, Pub. L. 97-248, sec.
402(a), 96 Stat. 648, and are generally applicable to partnership
taxable years beginning after Sept. 3, 1982.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011