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The criminal charges included fraud, mail fraud, bankruptcy
fraud, and money laundering. The essence of the criminal charges
was that Hoyt had victimized approximately 4,000 investors,
including petitioners.
Petitioners
On their income tax returns beginning in 1984, petitioners
claimed losses and credits from their involvement in a cattle
investor partnership organized and operated by Hoyt and
identified as Shorthorn Genetic Engineering 1984-4 Ltd.
Petitioners also claimed that losses related to the Hoyt
partnership carried back to 1981, 1982, and 1983. Additional
deductions were claimed on petitioners’ returns for 1985 and
1986. As a result of delays caused by Hoyt’s dealings with the
IRS and the various investigations of Hoyt, the taxes for the
years in issue were not assessed until sometime in 1998.
Section 6330 Proceedings
On March 21, 2005, the IRS sent to each petitioner a
separate Final Notice–-Notice Of Intent To Levy And Notice Of
Your Right To A Hearing for each of the years 1981, 1982, 1983,
1984, and 1986. A Request for a Collection Due Process Hearing
was filed on behalf of petitioners on or about April 7, 2005.
Petitioners’ request for a section 6330 hearing included the
following arguments:
Mr. and Mrs. Bergevin believe that the Notice of Intent
to Levy is improper for the following reasons:
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