- 6 - Neither petitioner nor Mr. Bartak sought advice from a tax professional about the Hoyt partnerships before or after investing. Arvis W. Drowns, Jr., petitioner and Mr. Bartak’s tax return preparer before they invested in the Hoyt partnerships, did not review the Hoyt partnerships promotional materials. Petitioner never suggested seeking the advice of someone outside the Hoyt organization regarding the Hoyt partnerships. Mr. Bartak never consulted, or stated that he had consulted, with an independent tax professional regarding the Hoyt partnerships. Mr. Bartak did not force petitioner to invest in, or sign documents related to, the Hoyt partnerships. There was no hostility or threats. Mr. Bartak wanted petitioner to sign the documents because he wanted to make sure she was fully aware of the investments. Petitioner signed checks, including checks on accounts held jointly by petitioner and Mr. Bartak, made payable to Hoyt partnerships or the Hoyt organization. One of the checks petitioner wrote was for the “audit pool”--a fund for Hoyt partners who were audited by the Internal Revenue Service (IRS). Petitioner and Mr. Bartak’s Other Investments In addition to the Hoyt partnerships, petitioner and Mr. Bartak had several other investments at the time they invested inPage: 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