River City Ranches #1 Ltd., Leon Shepard, Tax Matters Partner - Page 42

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               On October 13, 1989, during the CID’s above-mentioned                  
          investigation, the U.S. Attorney’s Office in Sacramento requested           
          that the CID review certain information and determine whether IRS           
          special agents from the CID should join in an ongoing grand jury            
          investigation of Jay Hoyt for possible violations of the Internal           
          Revenue laws.  On November 3, 1989, the IRS Regional Counsel’s              
          Office requested that IRS special agents be authorized to                   
          participate in the grand jury investigation.  On October 2, 1990,           
          the U.S. Attorney’s Office ended the grand jury investigation of            
          Jay Hoyt without an indictment.                                             
               On or about August 31, 1993, the CID commenced an                      
          investigation of Jay Hoyt for possible criminal violations of the           
          Internal Revenue laws due to his alleged misrepresentation of the           
          total number and value of purported cattle that the cattle                  
          partnerships allegedly owned.  The CID closed the investigation             
          on or about October 7, 1993, and did not recommend that the IRS             
          attempt to have Jay Hoyt prosecuted.                                        
               On or about September 8, 1995, the CID commenced an                    
          investigation of Jay Hoyt for possible criminal violations of the           
          Internal Revenue laws relating to the alleged shortage of cattle            
          from the Hoyt cattle partnerships.  The CID closed this                     
          investigation on September 29, 1995, and did not recommend that             
          the IRS attempt to have Jay Hoyt prosecuted.                                








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