- 18 - 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 aPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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