Dear Partner:

As you may know, our firm represents a number of partners from the Hoyt Partnership "debacle." In our efforts to ameliorate partners' tax liabilities and to recover monies from the IRS on their behalf, we have had the occasion to work very closely with the partnerships' attorney, Montgomery Cobb. We have found that the efforts of the partnership attorney have been crucial to the overall task of pushing the I.R.S. in every possible direction toward resolution of the cases. As the partner attorneys, we are able to file suits and claims that the partnership attorney cannot, and vice versa.

Thus, the combined effort of partner attorneys and the partnership attorney work to achieve the greatest possible coverage of issues and claims against the I.R.S. That said, we have found that the partners' financial support of the PDFT has been instrumental and necessary to putting forth the best case(s) against the I.R.S. It is, of course, your decision whether to financially support either or both the PDFT and individual partner attorney efforts. We would like, therefore, to take an opportunity to thank you for your support of our efforts and that of the PDFT.

Sincerely,

Wendy S. Pearson
Terri A. Merriam