- 14 - Around the time of petitioner’s divorce in 1986, she was informed that her partnership interest had been transferred from RCR #1 to a similar but separate partnership, River City Ranches #4 (RCR #4). Around this same time, petitioner personally began making substantial periodic cash payments to RCR #4; these payments were in addition to the indirect payments that petitioner was making to RCR #4 in the form of the tax refund checks that were being negotiated on her behalf. Petitioner continued investing in RCR #4 through at least 1995, and she continued claiming losses with respect to that investment on her income tax returns through that year. By letter dated June 9, 1995, petitioner was notified by the Portland, Oregon, office of the Federal Bureau of Investigation (FBI) that the FBI and United States Postal Inspection Service were: conducting an investigation into allegations that W.J. Hoyt & Sons and its affiliated entities, and certain associated individuals, engaged in conduct and/or practices that may be violations of federal criminal fraud statutes. Attached to this letter was a questionnaire pertaining to petitioner’s involvement in “one or more of the W.J. Hoyt & Sons investment programs.” Petitioner completed portions of this questionnaire. In answer to the question “How did you first hear of Hoyt & Sons or any of its related entities”, petitioner responded “Relatives were involved in livestock business and werePage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011