Walter Hoyt was convicted of 52 counts of mail fraud and bankruptcy fraud for taking more than $100 million from people who thought they had invested in legitimate tax shelter partnerships.

For many of Mr. Hoyt's victims, the conviction and sentencing provides only a shallow sense of satisfaction because the Internal Revenue Service is still disallowing tax deductions on their investments.

The IRS is trying to collect back taxes and interest on the money victims invested with Mr. Hoyt.

''It doesn't do a whole lot of good until the IRS acknowledges the tax crimes,'' Aiken resident Tom Emerson said. ''They still haven't accused Hoyt of any tax crimes, and it just makes no sense. It's hard for anyone to understand the reasons why the IRS is playing hardball with us unless there's something they do not want exposed.''

The IRS suspected Mr. Hoyt of fraud as early as 1980, when the agency began annual audits of the cattleman's partnerships. Despite mounting evidence, the agency didn't revoke his IRS-enrolled agent status - a top certification for non-IRS employees who pass IRS tax tests - until 1997.

IRS representatives refused to comment Wednesday on the sentencing, except to say the agency will work with investors on a swift resolution.

Portland lawyer Monty Cobb, one of several attorneys representing the Hoyt victims, said the IRS has chosen a strategy of self-vindication as a way of ''not having to acknowledge their mistakes.''

''The IRS has formally denied in tax court documents that these investors were defrauded,'' Mr. Cobb said. ''The IRS has, over a 20-year period, gotten itself into an extremely embarrassing situation ... and they've adopted a blame-the-victim strategy.''

Mr. Hoyt marketed his scams to engineers and utility employees. Many of his victims are from the Augusta area because of the large number of people employed at the Plant Vogtle nuclear power plant and Savannah River Site.

For more than 20 years, Mr. Hoyt formed investor partnerships and appointed himself the tax matters partner, giving him control over tax issues. He prepared returns and earned huge refunds on money-losing ranch operations.

Mr. Hoyt kept the returns and persuaded people to invest more of their money in the operation. Investors were promised they would see big returns in 10 to 15 years when the partnership's cattle herds were sold.

Reach John Bankston at (706) 823-3352 or jbanks15@hotmail.com.