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cases, the U.S. trustee moved in 1997 to have the bankruptcy
court substantively consolidate all assets and liabilities of
almost all Hoyt organization entities and all of the investor
partnerships. On November 13, 1998, the bankruptcy court entered
its Judgment for Substantive Consolidation, consolidating all the
above-mentioned entities for bankruptcy purposes. The trustee
then sold off what livestock the Hoyt organization owned or
managed on behalf of the investor partnerships.
Mr. Hoyt and others were indicted for certain Federal
crimes, and a trial was conducted in the U.S. District Court for
the District of Oregon. The District Court described Mr. Hoyt’s
actions as “the most egregious white collar crime committed in
the history of the State of Oregon.” Mr. Hoyt was found guilty
on all counts, and as part of his sentence in the criminal case
he was required to pay restitution in the amount of $102 million.
This amount represented the total amount that the United States
determined, using Hoyt organization records, was paid to the Hoyt
organization from 1982 through 1998 by investor-partners in
various investor partnerships.
II. Petitioner and His Investment
Petitioner has a college education with a bachelor of
science degree in engineering. During the year in issue,
petitioner was employed as a field engineer. At the time that he
invested in the Hoyt partnerships, petitioner did not have any
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Last modified: May 25, 2011