Susan L. Abelein - Page 11

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               Before petitioner and Mr. Abelein invested in the Hoyt                 
          partnerships, Mr. Abelein prepared the returns himself or had a             
          tax return preparer or accountant prepare the returns.  After               
          petitioner and Mr. Abelein invested in the Hoyt partnerships, the           
          Tax Office of W.J. Hoyt Sons Management Company prepared their              
          returns.  When Mr. Abelein received the completed returns from              
          the Hoyt organization, he looked over the returns and signed                
          them.  Petitioner also signed the returns.  Petitioner knew she             
          was not allowed to deduct expenses on the returns that she did              
          not incur and that it was important to review the returns before            
          she signed them.  Mr. Abelein did not threaten petitioner to                
          obtain her signature on the returns.                                        
               Petitioner could identify the Hoyt-related items on their              
          1985 and 1986 returns.  Petitioner even asked Mr. Abelein about             
          the numbers on their 1985 Form 3468, Computation of Investment              
          Credit, which accompanied their 1985 tax return, because she did            
          not understand where they came from.  In later years, petitioner            
          asked Mr. Abelein other questions about the effect of the                   
          investment on their tax returns, including “How can you legally             
          go back on your taxes?” and “How can you have so many deductions            
          when you really don’t have that many kids?”                                 
          The Hoyt Partnership Litigation and Settlement                              
               The Commissioner initiated audits of the Hoyt partnerships,            
          including but not limited to DGE, and sent appropriate notices to           






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Last modified: May 25, 2011