- 7 - as River City Ranches 85-2 (RCR 85-2). Petitioners were told by the Hoyt organization to ignore communications from the Internal Revenue Service (IRS) as they were merely harassing Hoyt investors. Petitioners continued investing in the Hoyt partnership through approximately 1994. Petitioners continued remitting their Federal income tax refunds to the Hoyt partnership until Mr. Hitchen retired from General Mills in 1991. Starting in approximately 1990, petitioners began making substantial out-of- pocket cash payments in response to various requests and “assessments” by the partnership. Petitioners also were required to pay additional amounts throughout the years representing tax return preparation fees. The losses and credits claimed by petitioners with respect to their taxable years 1984 through 1989 are discussed below; petitioners claimed a deduction for a partnership loss of $42,260 in 1990, but they did not claim a deduction for either a farming loss or a partnership loss in 1991. In a letter to petitioners dated February 6, 1992, Mr. Hoyt stated in relevant part: I have been notified by the General Partners office that your 1990 contribution is still past due. Because this balance of $3500 has not been paid we are beginning collection enforcement. Your partnership note authorizes us to repossess shares of unpaid partnership units. When your cattle, sheep or truck units are taken back the Internal Revenue Service regulations require us to notify them you have debt relief income of about 13Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011