- 6 - 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 powersPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011