Roy and Antonette Barnes - Page 3

                                        - 3 -                                         
          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.                                  







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011