Gary and Johnean Hansen - Page 3

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          these partnerships was Timeshare Breeding Service 1989-1 (TBS).             
          Hoyt was TBS’s general partner and tax matters partner, and TBS             
          was subject to the unified audit and litigation procedures of the           
          Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. 97-248,           
          sec. 402(a), 96 Stat. 648.  Hoyt was convicted on criminal                  
          charges relating to the promotion of TBS and other partnerships.            
               Petitioners’ claim to losses and credits passing to them               
          from TBS resulted in the underreporting of their 1989 taxable               
          income.5  On October 22, 2002, 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 tax (and any related amount) that they owed for 1989.  The           
          notice advised petitioners that they were entitled to a hearing             
          with Appeals to review the propriety of the proposed levy.                  
               On November 18, 2002, petitioners asked Appeals for the                
          referenced hearing.  On January 11, 2005, Linda Cochran                     
          (Cochran), a settlement officer in Appeals, held the hearing with           
          petitioners’ counsel.  Cochran and petitioners’ counsel discussed           
          two issues.  The first issue concerned petitioners’ intent to               
          offer to compromise their 1987 through 1998 Federal income tax              

               5 Petitioners’ claim to losses and credits passing to them             
          from other Hoyt partnerships was the subject of an affected items           
          proceeding in this Court.  See Hansen v. Commissioner, T.C. Memo.           
          2004-269, affd. 471 F.3d 1021 (9th Cir. 2006).                              

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