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of attorney, partnership agreements, and a debt assumption
agreement.
Petitioner was not forced by Christopher to invest in the
Hoyt partnerships. Petitioner agreed to participate in the Hoyt
investments upon Christopher’s encouragement.
After becoming investors in a Hoyt partnership, petitioner
and Christopher attended several meetings with other Hoyt
partners. Petitioner made calls to the Hoyt organization.
In 1984, petitioner and Christopher paid no “cash” to SGE
1984-2. In 1985, petitioner and Christopher paid $19,999 in
“cash” to SGE 1984-2. By 1986, petitioner and Christopher had
paid at least $29,298 in “cash” to SGE 1984-2.
From 1985 through 1996, numerous checks, drawn on petitioner
and her husband’s joint checking account, were made payable to a
Hoyt partnership. These checks totaled almost $25,000.
Additional checks, totaling over $14,000, made payable to a Hoyt
partnership, were drawn on an account owned by Christopher and
the Verna Irene Doyel Trust.
Tax Returns
Petitioner and Christopher filed joint Federal income tax
returns for 1982, 1983, 1984, 1985, and 1986. Petitioner signed
each of these returns.
On their joint income tax return for 1982, petitioner and
Christopher reported $40,609.38 in wages. Attached to this
return was a Form W-2, Wage and Tax Statement, for Christopher
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