Ann E. Bartak - Page 25

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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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