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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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