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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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