- 3 - should be limited to the administrative record under the Court of Appeals opinion in Robinette v. Commissioner, 439 F.3d 455 (8th Cir. 2006), revg. 123 T.C. 85 (2004). In view of the years for which the interest on the underlying liabilities is accruing, we have decided to proceed with our opinion in this case. The issue for decision is whether it was an abuse of discretion to refuse petitioners’ offer-in-compromise and to determine that collection efforts should proceed. Background Although the record is voluminous, we do not here recount in detail the background of the Hoyt partnerships; that has been restated many times. We simply outline those facts necessary to an understanding of petitioners’ arguments to the settlement officer who conducted the section 6330 hearing and to the Court. Walter J. Hoyt III (Hoyt or Jay Hoyt) Many facts and documents have been stipulated in six separate stipulations filed in this case, which are incorporated in our findings by this reference. Background facts concerning the venture in which petitioners invested are described in “narrative stipulations” relating to Hoyt. From about 1971 through 1998, Hoyt organized and promoted to thousands of investors more than 100 cattle breeding partnerships and some sheep partnerships. The partnerships were all organized and operated in essentially the same manner. In addition, all of thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008