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Petitioner and Mr. Abelein handled IRS correspondence in the
same way as the Hoyt materials so that it was available to
petitioner at all times.
Over the years, petitioner told Mr. Abelein she did not want
to be a part of the partnership anymore. Despite her concerns
and notice of the partnership audits, petitioner made no efforts
to extricate herself from the Hoyt partnership and continued to
invest in the organization with Mr. Abelein.
Petitioner’s Innocent Spouse Claim
On or around July 7, 2000, petitioner submitted a Form 8857,
Request for Innocent Spouse Relief (And Separation of Liability
and Equitable Relief), on which she requested relief pursuant to
section 6015(b) for the taxable years 1982 through 1996.8
On August 23, 2001, respondent sent petitioner a preliminary
determination letter denying petitioner’s request for relief
under section 6015(b), (c), and (f) for taxable years 1982
through 1986. Respondent denied relief on the basis that (1)
Petitioner had actual knowledge or reason to know of the item
giving rise to the understatement; (2) petitioner did not show
7(...continued)
for 1984; $3,141 for 1985; and $2,992 for 1986.
8On Nov. 14, 2000, respondent sent petitioner a letter
indicating her request for relief for 1987 through 1997 was
premature. On Aug. 9, 2001, respondent sent petitioner a letter
indicating her request for relief for tax years 1993 and 1995 was
premature.
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