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The brochure discussed the potential of audits by the Internal
Revenue Service and stated that the Commissioner would brand the
Hoyt partnerships “an abuse” and would subject the partnerships
to “automatic” and “constant” audit. The brochure stated the
Hoyt organization alone should be trusted to prepare each
partner’s tax returns.
From July 1, 1988, through September 30, 1992, petitioner
paid the Hoyt organization the following amounts on the
accompanying dates:
Date of Payment Amount
July 1, 1988 $7,000
Jan. 4, 1991 6,000
Dec. 17, 1991 4,000
Dec. 17, 1991 5,000
Sept. 2, 1992 4,785
26,785
4. Petitioner’s Federal Income Tax Returns
Petitioner’s 1988, 1989, 1990, and 1991 Federal income tax
returns were prepared by tax preparation entities operated by
Hoyt. Petitioner provided those entities with his personal
information, such as wages, interest, dividends, mortgage
interest, and real estate taxes, and the Hoyt organization
provided the tax preparers with the amounts of losses and other
tax attributes to be reported as distributed from the Hoyt
partnerships. Petitioner signed and filed his 1988, 1989, 1990,
and 1991 tax returns on the following dates:
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Last modified: November 10, 2007