Glenn A. Mortensen - Page 4

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          before the Internal Revenue Service (IRS) until he was                      
          disenrolled as enrolled agent in 1998.                                      
               Beginning in February 1993, respondent generally froze and             
          stopped issuing income tax refunds to partners in the investor              
          partnerships.  The IRS issued prefiling notices to the investor-            
          partners advising them that, starting with the 1992 taxable year,           
          the IRS would disallow the tax benefits that the partners claimed           
          on their individual returns from the investor partnerships, and             
          the IRS would not issue any tax refunds these partners might                
          claim attributable to such partnership tax benefits.                        
               Also beginning in 1993, an increasing number of investor-              
          partners were becoming disgruntled with Mr. Hoyt and the Hoyt               
          organization.  Many partners stopped making their partnership               
          payments and withdrew from their partnerships, due in part to               
          respondent’s tax enforcement.  Mr. Hoyt urged the partners to               
          support and remain loyal to the organization in challenging the             
          IRS’s actions.  The Hoyt organization warned that partners who              
          stopped making their partnership payments and withdrew from their           
          partnerships would be reported to the IRS as having substantial             
          debt relief income, and that they would have to deal with the IRS           
          on their own.                                                               
               On June 5, 1997, a bankruptcy court entered an order for               
          relief, in effect finding that W.J. Hoyt Sons Management Company            
          and W.J. Hoyt Sons MLP were both bankrupt.  In these bankruptcy             






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