Pamela J. Ellison - Page 4

                                        - 4 -                                         
          Mr. Ellison talked with petitioner about the Hoyt partnerships              
          and showed her Hoyt partnerships promotional materials.                     
          Petitioner attended a Hoyt investor meeting.                                
               Petitioner was not interested in investing in the Hoyt                 
          partnerships.  Petitioner was skeptical regarding how an                    
          investment in the Hoyt partnerships would reduce her tax                    
          liability and would generate large tax refunds.  Petitioner did             
          not think it would work.                                                    
               Mr. Ellison sought advice from an attorney about the Hoyt              
          partnerships.  The attorney told Mr. Ellison that it was a risky            
          investment, but that if the Hoyt organization did what it said it           
          would do that it was legal.                                                 
               Mr. Ellison told petitioner that he investigated the Hoyt              
          partnerships.  Petitioner did not know, or ask Mr. Ellison, who             
          he had talked to or how he had obtained his information (i.e.,              
          whether it was from an attorney, a tax professional, someone                
          outside or inside the Hoyt organization, a co-worker of Mr.                 
          Ellison, etc.).  Petitioner never suggested seeking the advice of           
          someone outside the Hoyt organization regarding the Hoyt                    
          partnerships.                                                               
               Mr. Ellison persuaded petitioner to invest in the Hoyt                 
          partnerships.  There was no hostility or threats.  Mr. Ellison              
          did not force petitioner to invest in the Hoyt partnerships.                
          Petitioner signed the Hoyt partnerships investment documents.  In           






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011