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Hoyt organization investor partnerships were marketed and
promoted in an identical fashion. As the general partner
managing each partnership, Hoyt was responsible for and directed
the preparation of the tax returns of each partnership, and he
typically signed and filed each return. Hoyt used his status as
an enrolled agent with the Internal Revenue Service (IRS) to
promote the partnerships.
The Hoyt partnerships were ultimately audited as “a tax
shelter project”. Most of the partnerships were audited under
the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA),
Pub. L. 97-248, section 402(a), 96 Stat. 648. See secs. 6221-
6231. Hoyt acted as the tax matters partner (TMP) during the
audit and until his removal by this Court in certain cases,
commencing in 2000.
On or around April 23, 1984, a criminal investigation
reference concerning Hoyt was made. On April 21, 1986, a
recommendation for prosecution was made. Those recommendations,
however, did not lead to prosecution. On or about July 28, 1989,
a second reference for criminal investigation was made. In 1990,
a grand jury investigation of Hoyt concluded without an
indictment. Hoyt’s status as an enrolled agent was revoked in
1998.
A criminal indictment was filed on June 2, 1999, and Hoyt
was convicted of various criminal charges on February 12, 2001.
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Last modified: March 27, 2008