- 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
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