River City Ranches #1 Ltd., Leon Shepard, Tax Matters Partner - Page 45

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          losses exceeding $200 million.”  United States v. Hoyt, 47 Fed.             
          Appx. 834, 837 (9th Cir. 2002).                                             
               Following the Government’s filing in late 1998 of the                  
          indictment against Jay Hoyt, respondent moved this Court to                 
          remove Jay Hoyt as TMP in many of the cattle and sheep                      
          partnership cases before the Tax Court.  In orders issued from              
          June 22, 2000, through May 15, 2001, this Court removed Jay Hoyt            
          as TMP in numerous cattle and sheep partnership cases, pursuant             
          to Rule 250(b).                                                             
          E.   Certain Agreements Extending the Period of Limitations That            
               Jay Hoyt and the IRS Executed                                          
               Jay Hoyt and the IRS executed agreements extending the                 
          period of limitations on assessments for certain taxable years of           
          RCR #2, RCR #3, RCR #4, RCR #5, and RCR #7.  Jay Hoyt executed              
          each of the extension agreements as TMP for the various sheep               
          partnerships.                                                               
               The partnership taxable year involved, the date upon which             
          the partnership filed its return for that year, the IRS extension           
          form used, the respective dates upon which Jay Hoyt and the IRS             
          executed the various forms, the date to which Jay Hoyt and the              
          IRS (in the form) agreed to extend the period of limitations, and           
          the date upon which respondent issued each partnership the FPAA             
          are as set forth below:                                                     








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