Hoyt Fiasco: $103M Heist + Kevin Brown's Criminal Cover-up
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     Why did the IRS lead prosecuting attorney in the Hoyt case quit in disgust?

The Hoyt Fiasco: Settlement Information

This letter went out to former Hoyt investors.

Please note: Mark Rosenbloom, mentioned in this letter, has since been discredited. It is not advisable to use his "services" in any way. He services some of his clients the way a bull services cows. While gladly accepting money from Hoyt victims who trusted him (and running up the tab), he thought he could not be overheard when he told his assistant, "These Hoyt people deserve whatever they get" but he was overheard saying exactly that. His behavior reflected this sentiment and several of his clients when comparing notes found many anomalous instances of incompetence or perhaps deliberate errors.

Shealy, Pearson, Merriam, and the others listed below (exclusive of Mark "Rotten Apple" Rosenbloom) notably had the opposite attitude and genuinely care(d) about their clients. These people set the standard for what an attorney should aspire to be.

October 4, 2000

To: Hoyt Partners
RE: Hoyt Tax Court Litigation Settlement

Dear Former Hoyt Investor:

I and this law firm represent the Petitioners in Tax Court litigation affecting the Hoyt investor partnerships. You have been listed as an investor in one or more Hoyt partnerships. Due to the way partnership records were kept (or not kept) and the way tax returns were filed, you may be listed as a partner by the IRS in partnerships that you did not know you had anything to do with.

We have recently received information that the IRS is about to make a settlement proposal which will be sent directly to each Hoyt partner. The fact that the IRS is making a proposal at all is a direct result of efforts by your fellow partners, who contribute to the Partnerships' Defense Fund Trust, and the attorneys who represent them, as well as our efforts in the Tax Court. However, we do not believe that this offer is acceptable without further negotiation with the IRS. We believe the IRS is making this offer directly to partners, in order to prevent a unified response to the offer. In other words, it is an attempt to "divide and conquer."

Our only chance to have real and meaningful settlement negotiations with the IRS is to present a unified response to this settlement proposal. Additionally, it is imperative that you have individualized legal advice on this settlement offer before you take any action. I can only represent your partnership-level interests. The following are the names and telephone numbers of attorneys who are currently active in representing former Hoyt partners, and who are already familiar with the issues in these cases:

  • Doug Azar Attorney at Law
    2539 Wyoming NE
    Albuquerque, NM 87112
    Telephone: 505-332-4028

  • Christopher D. Hatfield Attorney at Law
    Hurley, Lynch & Re, P.C.
    747 SW Industrial Way
    Bend, OR 97702
    Telephone: 541-317-5505

  • Vincent J. Lombardo Attorney at Law
    1600 Rockefeller Building
    614 Superior Avenue, NW
    Cleveland, OH 44113
    Telephone: 216-621-0400

  • PMK
    Pearson, Merriam & Kovach
    216 First Avenue South, Suite 300
    Seattle, WA 98104
    Telephone: 206-382-0590

  • Mr. Mark Rosenbloom Attorney at Law
    220 W. Huron Street, 6th Floor
    Chicago, IL 60610
    Telephone: 312-587-8300

  • Arthur Shealy Attorney at Law
    325 Georgia Avenue
    North Augusta, SC 29841
    Telephone: 803-278-5149

I urge you to contact one of these attorneys or another attorney as soon as possible. You may also wish to contact Gary Blackburn, the Trustee of the Partnerships' Defense Fund Trust (PDFT). The PDFT, through the partners that contribute to it, has funded most, if not all, of the legal effort in the tax court cases which has forced the IRS to make a settlement proposal. If you are not already a PDFT contributor, you should contact Gary Blackburn to learn how the PDFT can assist you. Mr. Blackburn can be reached by telephone at the PDFT Hotline, 503-525-8849 or by mail at Partnerships' Defense Fund Trust, PO Box 299, Orovada, NV 89425.

It is crucial that the IRS settlement proposal be met with a unified response if we are going to have any chance of negotiating more favorable terms. If the IRS is successful in fragmenting the response from former Hoyt Partners, then the settlement will be nothing more than a "take-it-or-leave-it" offer, much like the earlier "906" settlements. Now that our long and strenuous efforts have opened the door, you must act together to be sure this is an opportunity and not a trap.

The records available indicate you have not settled all tax years with the IRS. If you have already settled all tax years, please disregard this letter.

Very truly yours,


Montgomery W. Cobb MWC:csd cc: Gary Blackburn All Partners' Attorneys


Last updated: Friday, October 09, 2020

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