Ann E. Bartak - Page 16

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          printout for Hoyt partnerships taxable years related to                     
          petitioner and Mr. Bartak; copies of subscription agreements,               
          powers of attorney, and partnership agreements signed by                    
          petitioner and Mr. Bartak; copies of Schedules K-1 issued to                
          petitioner and Mr. Bartak from the Hoyt partnerships; and copies            
          of checks signed by petitioner or Mr. Bartak made payable to Hoyt           
          partnerships.                                                               
               On November 28, 2000, petitioner’s counsel mailed respondent           
          a supplement to petitioner’s section 6015 claim.  Ms. Halbert               
          reviewed and considered all the materials and information                   
          petitioner submitted regarding her section 6015 claim.                      
               On August 10, 2001, Ms. Halbert prepared a written                     
          evaluation of petitioner’s claim.  Ms. Halbert concluded that               
          petitioner was not entitled to section 6015(b) relief because               
          petitioner knew of the Hoyt partnerships and owned the item that            
          gave rise to the deficiency (i.e., the Hoyt partnerships).  Ms.             
          Halbert concluded that there were no factors favoring granting              
          section 6015(f) relief and the following factors weighed against            
          granting section 6015(f) relief:  (1) Lack of economic hardship,            
          (2) the liability was not solely attributable to the                        
          nonrequesting spouse, and (3) the requesting spouse had knowledge           


               8(...continued)                                                        
          tax shelter project”.  The Hoyt tax shelter project examined Hoyt           
          partnerships.  Ms. Ritchie assisted District Counsel in preparing           
          Hoyt partnerships cases for trial.                                          





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