Ann E. Bartak - Page 6

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               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 in           









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