River City Ranches #1 Ltd., Jeffry Bergamyer, Tax Matters Partner - Page 21

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               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                   
               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 sold            

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