1. a. CSRA
Partner Group Task Assignment List
1. b. CSRA Partner Group Mail Clerks
2. a. Does
This Affect You?
2. b. Package Contents
3. CSRA
Partner Group
4. Monty Cobb letter to National Taxpayer
Advocate
Attachment 1:
CSRA Partner Group Task Assignment List
CSRA Partner Group
* Attorney Arthur Shealy
* Representative Identified on Procedure Hardcopy
* Chairperson Identified on Procedure Hardcopy
* Address Book Identified on Procedure Hardcopy
* Treasurer Identified on Procedure Hardcopy
* Coordinator Identified on Procedure Hardcopy
* Postman Identified on Procedure Hardcopy
Click here to see the mail clerks.
Attachment
2: Does the Hoyt Investment Fiasco Affect You?
The following is informational and should be verified by an attorney
Bankruptcy
By amending returns and getting assessed by the IRS for the amended returns, partner may
file for bankruptcy protection after the 8-month waiting period. Bankruptcy Court would
then consider relief of all bills except for last three years. If you declare bankruptcy
without being assessed for disputed years, you may be assessed again.
906s (Letters from IRS to Congressional Offices)
Recently, the Bankruptcy Court ruled that certain settlement agreements entered into with
partners, who were before Tax Court, were invalid because the agreement (Form 906) was
signed by the Associate Chief of Appeals, whom the Bankruptcy Court determined did not
have the authority to execute. Because the Bankruptcy Court found the settlement agreement
(Form 906) to be invalid, the assessment was determined to be erroneous and could result
in barred assessments. If the Court ruling is upheld in future litigation, the assessments
made prior to a Court decision would be erroneous. Although this Bankruptcy case was not
appealed, the IRS does not agree with the decision. "Future litigation brought about
by this decision may result in our (IRS) appeal."
Forms 906 settlement agreements have been entered into after Court Decisions have been
entered. In these cases, the Forms 906 are considered as claims and are sent to the Ogden
Service Center for recomputation of the tax liabilities.
Richard Pooley to National TAO
A recent Second Circuit Court of Appeal decision published 6-26-98, Transpac Drilling
Venture v. Commissioner, 147 F.3d 221, has held that TMPs lose their authority to
bind the partnerships and extend an assessment period when they became targets of a
criminal investigation. This is exactly on point with the waiver extensions secured from
Hoyt while IRS had an on going criminal investigation of him. Attorney Curtis Berner has a
Hoyt investor case with the same issue in the Ninth Circuit, docket #9354-96 titled
Richard and Marilyn Phillips v. Commissioner. I have followed the case and attended court
sessions. It is my impression this court will rule the same as the Second Circuit did in
the Transpac case. If so, most TEFRA related tax liability against Hoyt cattle investors
for assessments from 1983 on will be invalid and the tax periods subject to claims for
abatement and refund if payments have been made.
Department of Justice (Jay’s Indictment Case) to Judge Goldberg
This could affect all investors, regardless of position (Re-Opening of Record). The PDFT
is addressing this issue. It was during the presentation of evidence before the grand jury
and during witness interviews, that I became aware of the fact that false and/or
misleading testimony had been presented to the U.S. Tax Court in the Durham Farms
litigation. The investigation also revealed that false testimony had been presented to the
Tax Court in the case of Bales. et al. v. Commissioner, 1989-568, 58 T.C.M. (CCH) 431
(1989).
Attachment
3: CSRA Partner Group. Help Yourself by Helping Others
The CSRA Partner Group encourages you to write to your congressional leaders. Please help
us inform Congress of the infamous Hoyt Partnership Investment Fiasco.
The Hoyt Investors have never utilized their greatest strength. That strength is the
number of investors located in several states (40+) having the right to inform their
Congressional Leaders of IRS acts of misconduct toward the Hoyt Investor. We are going to
use a special package as the basis for utilizing this strength:
Package Contents
01. CSRA Partner Group Policy
02. Richard Pooley Letters
03. Cobb (PDFT) Package to National TAO (462 pages of factual evidence supporting our
claims)
04. Information from IRS to our Congressional Leaders
05. Bales Opinion
06. Transpac Opinion
07. Phillips Case Information
08. CSRA Partner Group Meeting Handouts
09. Tax Court Fraud Information
10. Filed Grand Jury Indictments
11. CSRA Partner Group Attorney Letters
12. Partner Congressional and TAO Letters (examples)
13. Congressional and TAO Addresses
14. Information from Networked Attorney's (if available)
15. Last Known Partner(s) Name amp Address within your State
Attachment
4: Monty Cobb letter of 08OCT98
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