- 9 -
Year of Tax Return Date Signed Date Filed
1988 Apr. 27, 1989 May 1, 1989
1989 June 1, 1990 June 4, 1990
1990 June 20, 1991 June 24, 1991
1991 Sept. 30, 1992 Oct. 2, 1992
Petitioner did not make any meaningful inquiry to find a tax
professional independent of the Hoyt organization to prepare or
review the Hoyt organization’s preparation of those returns.
Petitioner’s 1988 through 1991 tax returns reported the
following relevant items:
1988 1989 1990 1991
Wages $69,612 $71,538 $94,995 $99,979
Taxable interest 449 958 1,129 2,030
Refund of State and
local income taxes 843 3,694 1,789 3,173
Capital gains (losses) 5,311 (3,000) 308 -0-
Farm income -0- -0- -0- 25,094
Losses from Hoyt
partnerships 40,414 31,069 55,941 92,961
Losses from other
partnerships -0- 524 2,413 2,857
Total income 35,801 41,597 39,867 34,458
Tax liability 664 1,601 1,189 17
Withholdings 11,378 3,024 5,039 4,070
Refund 10,714 1,423 3,850 4,053
The losses reported as flowing from the Hoyt partnerships were
broken down as follows:
Partnership 1988 1989 1990 1991
TBS $1,424 $3,560 $3,560 -0-
DSBS 87-C 38,990 -0- 18,810 -0-
TBS 89-1 -0- 127,509 33,571 2$92,961
Total 40,414 31,069 55,941 92,961
1 This partnership loss was attributable to a depreciation
adjustment on property placed in service after 1986.
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