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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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