- 16 - 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.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011