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Expense item Monthly Expense
Food, clothing and misc. $2,450
Housing 2,421
Transportation 1,260
Health care 250
Taxes 2,038
Life insurance 105
Other secured debt 652
Other expenses 709
Total 9,885
The other expenses included $309 paid for their son’s private
schooling and $400 in attorney’s fees paid to the Pearson and
Merriam law firm for representation in Hoyt-related litigation.
In one of the letters, petitioners state that they are
offering to pay $40,413 “for all Hoyt-related years to be paid in
one lump sum payment * * *. This offer assumes that the IRS will
collect less than the Reasonable Collection Potential * * * based
on special circumstances and/or Effective Tax Administration.”
The letter also included “background” information regarding the
Hoyt partnerships and set out petitioners’ “special
circumstances”.
In the remaining two letters, petitioners provided more
“background” information and argued: (1) Their case was a
“longstanding” case; (2) the delay was attributable to the
criminal investigation of Hoyt; (3) interest should be
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Last modified: May 25, 2011