- 16 - 1987 1988 1989 1990 Income1 $65,750 $59,281 $61,239 $63,388 Partnership losses 142,950 28,972 37,249 41,470 Tax liability -0- 2,344 1,902 1,466 1Includes taxable income from wages, interest, and dividends. The Form 1045 and each of the returns from 1987 through 1990 were prepared by an individual affiliated with the Hoyt organization. By letter dated April 25, 1989, respondent notified petitioners that one of their Hoyt partnerships was under review. This letter stated in relevant part: Our information indicates that you were a partner in the above partnership [DSBS 87-C] during the above tax year [1988]. Based upon our review of the partnership’s tax shelter activities, we have apprised the Tax Matters Partner that we believe the purported tax shelter deductions and/or credits are not allowable and, if claimed, we plan to examine the return and disallow the deductions and/or credits. The Internal Revenue Code provides, in appropriate cases, for the application [of various penalties]. In January 1992, respondent mailed Hoyt investors, including petitioners, a letter regarding the application of section 469 (relating to passive activity loss limitations). That same month, Mr. Hoyt mailed a letter to investors, including petitioners, setting forth arguments that Hoyt investors materially participated in their investments within the meaning of section 469. In this letter, Mr. Hoyt stated that respondent’s assertions in the preceding letter were incorrect, and that the investors should do what was necessary to participate in their investment at least 100 or 500 hours perPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011