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partnership investment until they declared bankruptcy (sometime
after the years in issue).
On June 5, 2001, respondent mailed Christopher a letter
notifying him of petitioner’s request for relief from joint and
several liability.
On October 26, 2001, respondent mailed petitioner a
preliminary determination with respect to petitioner’s request
for relief from joint and several liability for 1982 through
1986. Respondent determined that petitioner was not entitled to
relief pursuant to section 6015(b), (c), or (f).
On February 11, 2002, respondent mailed petitioner a notice
of determination that determined petitioner was not entitled to
relief from liability pursuant to section 6015(b), (c), or (f)
for 1982 through 1986 (notice of determination). On Form 886-A,
Explanation of Items, attached to the notice of determination,
regarding section 6015(b) respondent explained:
We have concluded that you had actual knowledge or
reason to know of the item giving rise to the
understatement. The following factors were considered
in reaching this conclusion:
• You signed one or more
partnership/subscription agreements/powers
of attorney with respect to the Hoyt
partnerships.
• You signed personal checks made payable to
W.J. Hoyt Sons or other Hoyt entity.
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