- 24 - Furthermore, it is clear that the Hoyt organization treated her, and Mr. Bartak, as a partner in the Hoyt partnerships. The Schedules K-1 the Hoyt organization issued regarding their investment in SGE 1983-1 and TBS #1 listed petitioner as a partner in these Hoyt partnerships. Finally, Mr. Bartak may have taken the initiative and played a more dominant role in deciding to invest in the Hoyt partnerships, but petitioner agreed to invest in the Hoyt partnerships and she did it jointly with Mr. Bartak. Petitioner testified that she thought that she and Mr. Bartak personally owned the cattle at the Hoyt ranches. Additionally, petitioner admitted, in her petition and the notice of election to participate in Shorthorn Genetic Engg. 1982-2, Ltd. v. Commissioner, T.C. Memo. 1995-515, to being a partner in SGE 1983-1. Accordingly, we conclude that the understatements are not attributable to the erroneous items of one individual filing the joint returns. See Ellison v. Commissioner, T.C. Memo. 2004-57, (investment in Hoyt partnership was attributable to the taxpayer requesting section 6015 relief because she was a partner in the Hoyt partnership); Doyel v. Commissioner, T.C. Memo. 2004-35 (same). The failure to meet the requirements of section 6015(b)(1)(B) is sufficient for us to find that petitioner doesPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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