Donald and Yvonne Clayton - Page 3

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               Beginning in 1985, 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                
          1985-4, Timeshare Breeding Services 1987-2, Timeshare Breeding              
          Services J.V., Timeshare Breeding Services 1989-1, and Shorthorn            
          Genetic Engineering 1985-5.  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 1982 through 1986 taxable income.  On               
          March 8, 2004, respondent mailed to petitioners a Form CP-90,               
          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 1982 through 1986.  The notice advised             
          petitioners that they were entitled to a hearing with Appeals to            
          review the propriety of the proposed levy.                                  
               On April 6, 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’           






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