The Hoyt Fiasco: A welcome message to legislators

Dear United States of America Congressional Leaders, You Have Constituents Needing Your Help.

Please Help Us.

We loaded this Website with information to help you understand our problems--your constituents' problems arising from the "Hoyt Partnership Investment Fiasco."

What was the objective of an office within an agency (IRS) of the US Government that allowed Jay Hoyt, Tax Matters Partner (TMP), to bind partners--when in fact that office was aware of a conflict of interest existed as early as 1980s? What was the purpose in causing tax bills so large the partner will never be able pay in his/her lifetime?

 
The Crux

Hornbook Agency and Partnership Law have long held that when a third party knows a partner has a conflict of interest with the partnership in a matter, that third party cannot rely on the words, actions, or signature of the conflicted partner to bind the partnership to any agreement regarding that matter. 2nd Circuit Court of Appeals Opinion (Transpac Drilling Venture 1982-12, et al., v. Commissioner of Internal Revenue, 98 TNT 130-6, 82 AFrR2d Par. 98-5016) identifies criminal investigation (CID) as a conflict of interest, clearly defines RULE of LAW, and that IRS is required to remove the binding authority of the partner at the time a conflict of interest is identified.

IRS has long denied any knowledge of early (1980s) conflicts of interest until recent evidence had been presented to Tax Court revealing early 1980s CID activity. Tax Court then ordered IRS to disclose all information relating to the CID activities. We understand the IRS has reported that their CID (early 1980s) records have been lost or destroyed. We have some of those lost or destroyed records that indicate early 1980s CID activity.

The above is only one of the many issues relating to the Hoyt Fiasco.

We need your help. And we need it now.

More than 3000 investors located in more than 45 states have experienced catastrophic financial failure. Thus, broken families, lost faith in an agency of our government, development of poor health, and loss by suicide are what stain this agency's hands. It's time to do some heavy duty cleaning.

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