Verna Doyel - Page 14

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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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