- 3 - 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’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