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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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