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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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Last modified: May 25, 2011