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Act of 1982, Pub. L. 97-248, sec. 402(a), 96 Stat. 648. Hoyt was
convicted on criminal charges relating to the promotion of this
and other partnerships.
Petitioners’ claim to the losses and credits resulted in the
underreporting of their 1981 through 1986 taxable income. On
December 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.
On January 14, 2004, petitioners asked Appeals for the
referenced hearing. On June 8, 2005, Linda Cochran (Cochran), a
settlement officer in Appeals, held the hearing with petitioners’
counsel. Cochran and petitioners’ counsel discussed petitioners’
intent to offer to compromise their 1981 through 1986 Federal
income tax liability to promote effective tax administration.
Petitioners contended that Appeals should accept their offer as a
matter of equity and public policy. Petitioners stated that it
took a long time to resolve the Hoyt partnership cases and noted
that Hoyt had been convicted on the criminal charges.
On June 8, 2005, petitioners tendered to Cochran on Form
656, Offer in Compromise, a written offer to pay $83,213 to
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Last modified: May 25, 2011