Ingrid Capehart - Page 45

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          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,               






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