Verna Doyel - Page 18

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          T.C. 306, 313 (2002).                                                       
               Respondent contends that petitioner failed to meet the                 
          requirements of subparagraphs (B), (C), and (D).  For the sake of           
          completeness, we shall discuss the application of 6015(b)(1)(B),            
          (C), and (D).  See Jonson v. Commissioner, supra at 119.                    
                    1.   Section 6015(b)(1)(B):  Attributable to One Spouse           
               Petitioner admits that the Hoyt investment caused the                  
          erroneous items on the returns.  Petitioner, however, contends              
          that the Hoyt investments are not attributable to her.                      
               Petitioner was a joint investor with Christopher in the Hoyt           
          investments.  She signed documents relating to her and                      
          Christopher’s investment in the Hoyt investments.  See Hayman v.            
          Commissioner, 992 F.2d 1256, 1260-1261 (2d Cir. 1993), affg. T.C.           
          Memo. 1992-228.  From the inception, the documents listed the               
          Hoyt investment as a joint investment of petitioner and                     
          Christopher.                                                                
               Additionally, checks were drawn on their joint account and             
          on a trust account apparently belonging to petitioner.  These               
          checks were made payable to Hoyt partnerships.                              
               Furthermore, it is clear that the Hoyt organization treated            
          her as a joint investor with Christopher in the Hoyt                        
          partnerships.  The Schedules K-1 the Hoyt organization issued               
          regarding their investment in SGE 1984-2 listed petitioner as a             








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