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          partnership agreement before she and Mr. Capehart signed it, and            
          she made phone calls to the Hoyt organization on several                    
          occasions to obtain answers to both her own and Mr. Capehart’s              
          questions about their investments.  Regardless of whether Mr.               
          Capehart played a dominant role in the decision to invest in the            
          Hoyt partnerships or whether petitioner, at times, was simply               
          following Mr. Capehart’s orders, the fact that petitioner                   
          ultimately agreed to become a partner and participated in                   
          managing the investment is sufficient for us to find that the               
          erroneous items giving rise to the understatements of tax are               
          items of both petitioner and Mr. Capehart.  Bartak v.                       
          Commissioner, T.C. Memo. 2004-83; Ellison v. Commissioner, supra;           
          see also Mora v. Commissioner, 117 T.C. at 290; Doyel v.                    
          Commissioner, T.C. Memo. 2004-35.                                           
               Petitioner argues that the facts of this case are                      
          distinguishable from Bartak and Doyel because Mr. Capehart                  
          coerced petitioner into participating in the investment,                    
          controlled all aspects of the investment, and acted in a                    
          deceitful and domineering manner towards petitioner with regard             
          to partnership matters.  However, the record is lacking in                  
          credible evidence to support petitioner’s allegations.  Although            
          Mr. Capehart initiated the investment in the Hoyt partnerships,             
          he never persuaded petitioner to participate in the investment by           
          coercing, deceiving, or threatening her.  To the contrary, Mr.              
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