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• You signed other correspondence/documents
relating to the Hoyt partnerships.
• The size of the loss/deduction in relation
to the income reported on the return would
reasonably put you on notice that further
inquiry would need to be made.
• You have not shown that you satisfied your
duty of inquiry at the time the return was
prepared and signed to make sure the
return was correct.
• Your investment in the Hoyt partnerships
was a joint investment with your spouse
giving you actual knowledge of the item
giving rise to the deficiency.
You cannot claim relief under section 6015(b) with
respect to your own erroneous items and you have not
shown that the erroneous items are attributable to your
spouse.
You have not shown that it would be inequitable, taking
into account all of the facts and circumstances, to
hold you liable for the deficiency attributable to the
understatement.
Respondent also explained why petitioner did not qualify for
relief under section 6015(c). Regarding section 6015(f),
respondent wrote: “You have not shown that it would be
inequitable, taking into account all of the facts and
circumstances, to hold you liable for the deficiency attributable
to the understatement.”
On or about April 9, 2002, Ms. Sneed forwarded petitioner’s
case to respondent’s Appeals Office. Appeals Officer Gloria
Flandez was assigned to review petitioner’s case. In November
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