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liabilities for 1992, 1993, 1994, and 1997. On October 4, 2006,
respondent’s Motion for Summary Judgment was filed. The issues
remaining for our consideration are (1) whether this case is ripe
for summary judgment; and (2) whether petitioner is barred by the
doctrine of res judicata from seeking section 6015 relief, or
more particularly, whether she “meaningfully participated” in two
prior Tax Court proceedings which resolved her tax liabilities
for the 1992, 1993, 1994, and 1997 tax years.
Background
Petitioner and her former husband (the Moores) filed joint
Federal income tax returns for their taxable years 1992, 1993,
1994, and 1997. On each of those joint returns, the Moores
claimed partnership losses from cattle breeding. The
partnerships were formed, promoted, and operated by Walter J.
Hoyt, III.2
2 From about 1971 through 1998, Hoyt organized, promoted,
and operated more than 100 cattle breeding partnerships.
Hoyt also organized, promoted, and operated sheep breeding
partnerships. From 1983 to his subsequent removal * * *
[around 2000], Hoyt was the tax matters partner of each Hoyt
partnership. From approximately 1980 through 1997, Hoyt was
a licensed enrolled agent, and as such, he represented many
of the Hoyt partners before the Internal Revenue Service
(IRS). In 1998, Hoyt’s enrolled agent status was revoked.
Hoyt was convicted of various criminal charges in 2000.
Johnson v. Commissioner, T.C. Memo. 2007-29.
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