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printout for Hoyt partnerships taxable years related to
petitioner and Mr. Bartak; copies of subscription agreements,
powers of attorney, and partnership agreements signed by
petitioner and Mr. Bartak; copies of Schedules K-1 issued to
petitioner and Mr. Bartak from the Hoyt partnerships; and copies
of checks signed by petitioner or Mr. Bartak made payable to Hoyt
partnerships.
On November 28, 2000, petitioner’s counsel mailed respondent
a supplement to petitioner’s section 6015 claim. Ms. Halbert
reviewed and considered all the materials and information
petitioner submitted regarding her section 6015 claim.
On August 10, 2001, Ms. Halbert prepared a written
evaluation of petitioner’s claim. Ms. Halbert concluded that
petitioner was not entitled to section 6015(b) relief because
petitioner knew of the Hoyt partnerships and owned the item that
gave rise to the deficiency (i.e., the Hoyt partnerships). Ms.
Halbert concluded that there were no factors favoring granting
section 6015(f) relief and the following factors weighed against
granting section 6015(f) relief: (1) Lack of economic hardship,
(2) the liability was not solely attributable to the
nonrequesting spouse, and (3) the requesting spouse had knowledge
8(...continued)
tax shelter project”. The Hoyt tax shelter project examined Hoyt
partnerships. Ms. Ritchie assisted District Counsel in preparing
Hoyt partnerships cases for trial.
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