- 25 - not qualify for relief pursuant to section 6015(b). Alt v. Commissioner, supra at 313. Although we need not decide whether petitioner satisfies the requirements of subparagraphs (C) and (D), for the sake of completeness, we shall briefly discuss the application of 6015(b)(1)(C) and (D). See Jonson v. Commissioner, supra at 119. This case is appealable to the U.S. Court of Appeals for the Ninth Circuit. Accordingly, with regard to section 6015(b)(1)(C), we apply the standard set forth in Price v. Commissioner, 887 F.2d 959, 963 (9th Cir. 1989), revg. an Oral Opinion of this Court. Golsen v. Commissioner, 54 T.C. 742 (1970), affd. 445 F.2d 985 (10th Cir. 1971). For reasons similar to those stated in Doyel v. Commissioner, supra, in which we applied the standards set forth in Price, petitioner had reason to know of the understatements. Contrary to her assertion, petitioner was involved in her family’s financial affairs. Although she may have not played a “dominant” role or been the initiator, the decision to invest in the Hoyt partnerships was made in consultation with petitioner. Petitioner was shown the documents relating to the Hoyt investments, signed Hoyt investment documents, was aware that the Hoyt investment was supposed to result in substantial tax savings, and attended Hoyt investor meetings.Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
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