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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.
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