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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 does
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