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undermine people simply trying to conduct a legitimate
and productive business.
In July 2001, petitioner testified in a proceeding in this
Court concerning her involvement in the Hoyt partnerships.6 In
this prior testimony, petitioner stated that when she and Mr.
Barnes made the investment, she was “drawn into” it because of
the involvement of the Barnes family, but that she felt that she
would be supporting the family operation and that it was her
“understanding that it was an investment in ranching * * * for
the long term”, one that would involve “some tax advantages”.
Petitioner further stated that she and Mr. Barnes “signed the
papers to enter the investment”. Finally, petitioner testified
that she believed at the time of the initial investment with Mr.
Barnes that she was investing in “an overall ranching business”.
Petitioner is employed by a winery named Madrona Vineyards,
where she is receiving monthly wages of $757. In addition,
petitioner is receiving pension income of approximately $2,186
per month. Petitioner lives with Lawrence Edwards (Mr. Edwards),
whom she married in 1997, in a residence that they purchased in
1991 for $225,000. Petitioner’s only long-term debt obligations
are the monthly mortgage payment on the residence, her portion of
which is $360, and a monthly payment on a 2001 Jeep Cherokee of
6The opinion of the Court in that proceeding, which involved
numerous consolidated cases, is River City Ranches #1 Ltd. v.
Commissioner, T.C. Memo. 2003-150.
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