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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.
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Last modified: November 10, 2007