Ann E. Bartak - Page 7

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          the Hoyt partnerships.  Petitioner and Mr. Bartak owned stock and           
          had invested in other partnerships.                                         
               One partnership petitioner and Mr. Bartak were partners in             
          invested in real estate.  Petitioner signed the documents for               
          this partnership investment.                                                
               Another partnership petitioner and Mr. Bartak were partners            
          in was Silver Screen Partners, Ltd.  This partnership invested in           
          movies that had not yet been made.                                          
               Another partnership petitioner and Mr. Bartak were partners            
          in was Cornerstone Investment.  Cornerstone Investment was formed           
          to operate a building materials yard.  Before they invested in              
          Cornerstone Investment, petitioner and Mr. Bartak visited                   
          Cornerstone Investment’s property and saw what Cornerstone                  
          Investment would be doing.                                                  
               Mr. Bartak also invested in limited partnerships and real              
          estate with his, and petitioner’s, son William.                             
          Documents from the Hoyt Organization                                        
               Petitioner and Mr. Bartak received promotional materials               
          from the Hoyt organization about the Hoyt partnerships.  Mr.                
          Bartak accumulated and maintained a file of all the documents he            
          received related to petitioner and Mr. Bartak’s investments in              
          Hoyt partnerships--whether from the Hoyt organization or from the           
          IRS.                                                                        








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