- 11 - 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 toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011