- 6 - true nature of the investment or that the claimed deductions were erroneous. Petitioner further stated, in relevant part, as follows: The recent conviction of Jay Hoyt establishes that Dorene had no actual knowledge, and thus no reason to know, that the claimed deductions were erroneous. The Hoyt investors were adjudged to be victims of a fraud, which by definition means they were deceived as to the nature of their investment and the facts giving rise to the disallowance of their investment related tax deductions. * * * The cover letter attached to petitioner’s administrative appeal stated that “We will provide additional factual information once we are contacted by the Appeals Officer.” Petitioner’s case was assigned to Appeals Officer Leslie Hackmeister. On or around April 10, 2002, petitioner’s counsel sent Appeals Officer Hackmeister a letter intended to supplement the factual and legal arguments of petitioner’s appeal. In the letter, petitioner’s counsel reiterated that Mrs. Bulger was not involved with the partnership investment, did not understand the partnership transactions, and that She certainly had no substantive knowledge of the underlying circumstances that caused the deductions to be denied, i.e., that the Hoyt organization did not have the 30,000 cattle it claimed it had and the misappropriation of capital contributions and IRA funds. Petitioner’s counsel concluded the letter by again offering additional information and documentation upon request and stating that everything “in this discussion can be backed up withPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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