- 21 - On December 12, 1991, the IRS met with Hoyt and requested extensions of the limitations periods for the 1987 and 1988 tax years for the partnerships. In a letter also dated December 12, 1991, the IRS informed Hoyt that it was considering imposing return preparer penalties. On December 13, 1991, Hoyt faxed a letter to the IRS stating that he would agree to sign the extensions if, and only if, the IRS would agree to extend the period for assessing any penalties against Hoyt and the other return preparers. In a letter dated December 18, 1991, the IRS informed Hoyt that it would not agree to postpone preparer penalty considerations in exchange for extensions for the partnerships. On May 21, 1992, the IRS sent a letter to Hoyt reconfirming its understanding that Hoyt would not consent to extend the assessment periods for the various partnerships unless “some way can be found to extend the assessment period for preparer penalties currently proposed.” In June 1992, the IRS and Hoyt reached an agreement whereby Hoyt consented to extend the limitations periods for the tax years 1987 though 1989, and the IRS agreed to delay assessing any preparer penalties for those same years until an FPAA was issued. After the Bales setback, the IRS decided to conduct a full headcount of the Hoyt livestock to prove that Hoyt was selling cattle and sheep to some partnerships that had already been soldPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NextLast modified: November 10, 2007