River City Ranches #1 Ltd., Jeffry Bergamyer, Tax Matters Partner - Page 17

                                       - 17 -                                         
          separate bank accounts and accurate accounting records for each             
          of the sheep partnerships, the IRS audited the partnership tax              
          returns as a group.  The IRS generally disallowed the partnership           
          tax benefits that each cattle and sheep partnership and their               
          respective partners claimed, resulting in those partnerships’ and           
          partners’ commencing numerous cases in this Court.                          
               After the initial IRS examinations of the many cattle and              
          sheep partnerships, several investigations by various Government            
          agencies were commenced relating to Hoyt’s activities.                      
               From 1984 through 1986, the IRS’s Criminal Investigation               
          Division (CID) conducted an investigation of Hoyt for allegedly             
          backdating documents to enable 12 investor-partners to claim                
          improper deductions and credits for 1980, 1981, and 1982.  On               
          July 31, 1986, the IRS District Counsel’s Office in Sacramento,             
          California, referred the matter to the Department of Justice                
          (DOJ) for prosecution.  The DOJ then forwarded the matter to the            
          U.S. Attorney’s Office in Sacramento for review and                         
          consideration.  On August 12, 1987, the U.S. Attorney’s Office              
          declined to prosecute Hoyt.                                                 
               In July 1989, a member of the IRS Examination Division team            
          (which had been examining the returns of many of the cattle and             
          sheep partnerships for the 1983 through 1986 taxable years)                 
          recommended that the IRS’s CID investigate Hoyt for allegedly               
          making and/or assisting in fraudulent or false tax return                   

Page:  Previous  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  Next 

Last modified: November 10, 2007