Verna Doyel - Page 6

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               The promotional materials further stated:  “If a Partner               
          needs more or less Partnership loss any year, it is arranged                
          quickly within the office without the Partner having to pay a               
          higher fee while an outside preparer spends more time to make the           
          arrangements.”                                                              
               The promotional materials clearly contemplated the tax                 
          shelter being audited by respondent--stating at one point:  “we             
          know we will be subject to constant audits by the I.R.S.”                   
               After Christopher reviewed the promotional materials,                  
          Christopher and petitioner talked about the Hoyt investment.                
          Petitioner did not fully understand how the Hoyt partnerships               
          worked because she did not carefully read the promotional                   
          materials.  Christopher, however, was always willing to discuss             
          the Hoyt investment with petitioner, and petitioner knew that               
          there were risks associated with the Hoyt investment.                       
               In 1984, petitioner and Christopher invested in Shorthorn              
          Genetic Engineering 1984-2 (SGE 1984-2), a Hoyt partnership.                
          Christopher signed the subscription agreements when they first              
          invested in the Hoyt partnership.  Under the heading of                     
          ownership, the line next to joint tenants with the right of                 
          survivorship was checked.                                                   
               In 1992, petitioner also signed subscription agreements                
          affirming and accepting the agreements Christopher had signed               
          earlier.  Included with the subscription agreements were powers             






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Last modified: May 25, 2011