River City Ranches #1 Ltd., Jeffry Bergamyer, Tax Matters Partner - Page 24

                                       - 24 -                                         
          1989, and to RCR #5 and RCR 85-2 for their tax years ending                 
          December 31, 1987 and 1988, and September 30, 1989.  On March 24,           
          1996, respondent issued an FPAA to RCR #4 for its tax year ending           
          December 31, 1984.                                                          
          D.   Hoyt’s Criminal Conviction                                             
               From 1993 through 1998, governmental agencies other than the           
          IRS, including the Securities and Exchange Commission (SEC), the            
          U.S. Postal Service (USPS), and the U.S. Trustee, also                      
          investigated Hoyt.  As a result of a referral for further                   
          investigation from the U.S. Attorney’s Office in Seattle,                   
          Washington, to the USPS, postal inspectors in late 1993 began an            
          investigation of Hoyt and the Hoyt organization for possible mail           
          fraud violations.                                                           
               During 1993 and 1994, the SEC conducted an ongoing                     
          investigation of Hoyt, but the SEC eventually closed its                    
          investigation and deferred to the USPS’s investigation of Hoyt              
          that had been commenced in late 1993.  In June 1995, postal                 
          inspectors seized numerous documents and records from the offices           
          of the Hoyt organization pursuant to a search warrant.                      
               On or about June 8, 1995, in the 32d Judicial District Court           
          for the Parish of Terrebonne, State of Louisiana, a group of                
          investors obtained an $11 million default judgment against Hoyt,            
          Management, MLP, and several cattle breeding partnerships for               
          fraud and other violations.  See Mabile v. Hoyt, No. 95-112222.             

Page:  Previous  17  18  19  20  21  22  23  24  25  26  27  28  29  30  31  Next 

Last modified: November 10, 2007