- 14 - total amount of these payments exceeds $40,000. These payments included the remittance of their tax refunds, the payment of quarterly and monthly installments on their promissory notes, special “assessments” imposed by the partnership, and contributions to purported individual retirement account plans maintained by the Hoyt organization. Petitioners continued contributing to the partnership even after they stopped receiving refunds from respondent. During and after the year in issue, petitioners received numerous documents purporting to show both the legitimacy of the Hoyt partnerships and the legality of the tax claims being made by the Hoyt organization. The Hoyt organization also portrayed employees of the IRS as incompetent and claimed that they were engaging in unjust harassment of Hoyt investors. Petitioners trusted these documents and believed and relied upon what the Hoyt organization told them. III. Petitioners’ Federal Tax Claims On June 10, 1991, petitioners filed a joint Federal income tax return for 1990, on which they reported the following: Wage income $46,162 Interest income 29 Pension and annuity income 8,422 Loss from DSBS 87-C (148,390) IRA contribution (2,000) Adjusted gross income (95,777) Tax liability 842 Overpayment 3,771 Upon filing their 1990 return, petitioners also filed a Form 1045, Application for Tentative Refund. On this form,Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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