River City Ranches #1 Ltd., Leon Shepard, Tax Matters Partner - Page 112

                                        - 97 -                                         
          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.                  






Page:  Previous  87  88  89  90  91  92  93  94  95  96  97  98  99  100  101  102  103  104  105  106  Next

Last modified: May 25, 2011