Hoyt Fiasco: $103M Heist + Kevin Brown's
Victim information, evidence, rules of law, IRS viewpoints
|Why did the IRS lead prosecuting attorney in the Hoyt case quit in disgust?|
|The Dunn letter is six pages long and about 61k. It
gives an inaccurate overview of the Hoyt Fiasco, but does contain some
truth. This is a letter from the IRS to a Senator who looked into the Hoyt
Fiasco and asked questions. We Hoyt victims do not agree with this
letter, but are posting it here because we are trying to present an
unbiased view of the situation.
This letter contains some false assertions. Compare the content with the facts, and you get a mismatch.
Note to partners: Download this letter and review. Should any partner receive IRS letter containing same information, contact one of the CSRA Mail Clerks (name /address of Congressional Office having received letter and IRS having sent letter). Front-Line attorneys are personally responding to this letter.
Click here to download the Dunn letter.
Here is part of the first page:
OFFICE OF CHIEF COUNSEL
DEPARTMENT OF THE TREASURY
JAN 31 2000
The Honorable [Senator]
Dear Senator [Last Name],
I am writing in response to your letter of December 10,1999, requesting that we review the concerns of your constituents, [partner]. The issue raised in [partner] correspondence involves the Internal Revenue Services (IRS) examination of what I will collectively refer to as the Hoyt Partnerships, which have been, and continue to be, the subject of extensive litigation.
In their letter, [partners] request that a line of communication be established with the National Taxpayer Advocate so that factual evidence may be considered "during review of our case." Presently, the tax issues with regard to the Hoyt partnerships are in litigation before the United States Tax Court. The Hoyt partnerships are subject to the unified audit and litigation procedures enacted by Congress as part of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA). Under the TEFRA procedures, all partners are parties to the proceedings regarding the proper determination of the items that are reported by the partnership. This is true both with regard to the administrative as well as the judicial stage of the proceedings. See Internal Revenue Code sections 6224(a) and 6226(c), respectively. As partners in a Hoyt partnership, [partner] have had the opportunity to participate in the litigation of these controversies and to provide factual evidence both to the Service as well as to the Tax Court. Despite the fact that the lead case has been fully submitted to the Tax Court for more than two years, we will continue to accept any new evidence that has not previously been considered, and such evidence will be given full consideration. Nonetheless, we expect a decision by the court on the merits of these cases to be forthcoming shortly. Furthermore, we have forwarded the taxpayers letter to the Taxpayer Advocate and he has indicated that his office will respond directly to Mr. Cobb (the taxpayers counsel).
Friday, October 09, 2020
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Disclaimer: The facts represented here are as accurate as a reasonable investigation can determine. Mindconnection hosts this site at no charge to the Hoyt victims, to expose this miscarriage of justice.