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even aware of the existence of (or the prospect of) a criminal
investigation.
In the instant case, Jay Hoyt executed virtually all of the
extensions in question when no criminal tax investigation of him
was being conducted. He executed extensions concerning the post-
1986 partnership years on various dates from February 1991
through March 1993. Earlier, in the summer of 1989, CID
commenced an investigation of Jay Hoyt for allegedly selling
nonexistent cattle to the Hoyt cattle partnerships, but this
investigation was completed by October 1, 1990. During this
investigation of Jay Hoyt, CID in October 1989 was asked to
review certain information and determine whether IRS special
agents should join in an ongoing grand jury investigation of Jay
Hoyt by the U.S. Attorney’s Office in Sacramento. This grand
jury investigation was closed on October 2, 1990. No prosecution
resulted from either the CID investigation or the grand jury
investigation.
Jay Hoyt executed the first of the extensions in question
concerning post-1986 partnership taxable years in mid-February
1991, several months after the closing of the above CID and grand
jury investigations in early October 1990. He executed the last
of these extensions concerning post-1986 partnership years in
early March 1993, over 5 months before CID’s next criminal tax
investigation of him commenced on or about August 31, 1993.
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