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accordingly. When the petition was filed, petitioners resided in
Pasco, Washington.
Beginning in 1984, petitioners’ Federal income tax returns
claimed losses and credits from their involvement in various
partnerships organized and operated by Walter J. Hoyt, III
(Hoyt). The partnerships were Shorthorn Genetic Engineering
1984-4, Timeshare Breeding Services 1989-1, Timeshare Breeding
Syndicate Joint Venture, Timeshare Breeding Service 1989-3 J.V.,
and Hoyt and Sons Trucking. Hoyt was each partnership’s general
partner and tax matters partner, and the partnerships were all
subject to the unified audit and litigation procedures of the Tax
Equity and Fiscal Responsibility Act of 1982, Pub. L. 97-248,
sec. 401, 96 Stat. 648. Hoyt was convicted on criminal charges
relating to the promotion of these partnerships.
Petitioners’ claim to the losses and credits resulted in the
underreporting of their 1981 through 1986 taxable income. On
August 16, 2003, respondent mailed to petitioners a Letter 1058,
Final Notice of Intent to Levy and Notice of Your Right to a
Hearing. The notice informed petitioners that respondent
proposed to levy on their property to collect Federal income
taxes that they owed for 1981 through 1986. The notice advised
petitioners that they were entitled to a hearing with Appeals to
review the propriety of the proposed levy.
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