Verna Doyel - Page 12

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          Agent Deborah Ritchie.4  Ms. Richie provided Ms. Sneed with a               
          computer printout for Hoyt partnership taxable years related to             
          petitioner and Christopher, copies of agreements and powers of              
          attorney signed by petitioner and/or Christopher, copies of                 
          Schedules K-1 issued to petitioner and Christopher from the Hoyt            
          partnerships, and copies of checks made payable to Hoyt                     
          partnerships drawn on petitioner’s and her husband’s joint                  
          checking account and on an account owned by Christopher and the             
          Verna Irene Doyel Trust.                                                    
               On April 20, 2001, petitioner sent a declaration of                    
          Christopher B. Doyel to the Cincinnati Service Center                       
          (Christopher’s declaration).  In Christopher’s declaration, he              
          stated:  “I decided to investigate the investment opportunity               
          with the Hoyt partnerships.  Initially, my spouse did not attend            
          any meetings, but, did read some promotional literature on the              
          Hoyt partnership investments.  After we were involved my spouse             
          did attend approximately three meetings.”  Christopher also                 
          stated that petitioner signed the subscription agreements and               
          that petitioner never asked any questions about the Hoyt                    




               4  Ms. Ritchie worked on the “Hoyt audit team” and the “Hoyt           
          tax shelter project”.  The Hoyt tax shelter project examined Hoyt           
          partnerships.  Ms. Ritchie assisted District Counsel in preparing           
          Hoyt partnership cases for trial.                                           







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