- 45 - determination for the reasons stated earlier in this opinion. The record adequately establishes that the Hoyt partnership investments made by petitioner and Mr. Capehart were joint investments and that petitioner actively participated in the making of those investments. This factor weighs against granting petitioner equitable relief under section 6015(f). b. Knowledge or Reason To Know For the reasons stated above in our analysis of the corresponding positive factor, we conclude that petitioner had reason to know of the items giving rise to the deficiencies in this case and/or failed to satisfy her duty of inquiry regarding the items. This factor weighs heavily against granting petitioner equitable relief under section 6015(f). Rev. Proc. 2000-15, sec. 4.03(2)(b). (This factor is an extremely strong factor weighing against relief.) c. Significant Benefit Petitioner argues that she did not significantly benefit beyond normal support from the Hoyt partnership losses and investment tax credit giving rise to the deficiencies. Respondent contends, however, that the SGE losses enabled petitioner and Mr. Capehart to increase their available cashflow for the years at issue by over $34,174 in tax savings, which they used to make their investments in several Hoyt partnerships, including SGE. In Doyle v. Commissioner, T.C. Memo. 2003-96,Page: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
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