- 30 -
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:
Page: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 NextLast modified: May 25, 2011