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FINDINGS OF FACT
The parties filed with the Court stipulations of fact and
accompanying exhibits. The stipulated facts are found
accordingly. Petitioners are husband and wife, and they resided
in Tucson, Arizona, when their petition was filed.
On their Federal income tax returns beginning in 1984,
petitioners claimed losses and credits from their investment in
several partnerships organized and operated by Walter J. Hoyt III
(Hoyt). The partnerships were subject to the unified audit and
litigation procedures of the Tax Equity and Fiscal Responsibility
Act of 1982, Pub. L. 97-248, sec. 402(a), 96 Stat. 648. Hoyt was
convicted on criminal charges relating to the promotion of these
partnerships.
Petitioners’ claim to the partnerships’ losses and credits
resulted in the underreporting of their personal 1984, 1985,
1986, and 1991 Federal income taxes. On November 13, 2003,
respondent mailed to petitioners a Letter 1058, Final Notice of
Intent to Levy and Notice of Your Right to a Hearing. The notice
informed petitioners that respondent proposed to levy on their
property to collect amounts owed as to their 1984, 1985, 1986,
and 1991 Federal income taxes; all of these amounts were
attributable to the just referenced underreporting of income.
The notice advised petitioners that they were entitled to a
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