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partnership. Petitioner stated that she did not consider herself
an investor in the partnership until the time of her divorce.
Around that time, petitioner had approached April Barnes to
inquire into the status of the investment. Petitioner asserts
that April Barnes informed her that she “could not” leave the
partnership, and that petitioner was subsequently forced into
accepting her status as an investor because of certain documents
which she was told she had signed, but with respect to which she
had no memory. Petitioner testified that she “had to” continue
claiming Hoyt-related losses from 1981 through 1995.
We do not accept these assertions by petitioner. Firstly,
petitioner’s version of events presented in her testimony and on
brief are belied by the version of events that she provided to
the FBI in 1995. In responding to the FBI questionnaire,
petitioner very clearly held herself out to be a willing partner
in the Hoyt partnership. She stated that she had been a partner
since 1980, and she defended the validity of her investment and
the Hoyt organization. Petitioner never stated that her status
as a partner started only after her divorce. Petitioner also
derided certain investors who had previously decided to abandon
their interests in the partnerships as engaging in “subversive
activities”.
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