Pamela J. Ellison - Page 5

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          1985, petitioner and Mr. Ellison invested in Durham Genetic                 
          Engineering 1984-2 (DGE 1984-2), one of the Hoyt partnerships.3             
               In 1985, petitioner and Mr. Ellison paid no “cash” to DGE              
          1984-2.  In 1986, petitioner and Mr. Ellison paid $20,750 in                
          “cash” to DGE 1984-2.                                                       
               Petitioner signed checks, on accounts held jointly by                  
          petitioner and Mr. Ellison, made payable to Hoyt partnerships or            
          the Hoyt organization.  Several of these checks were for                    
          thousands of dollars.                                                       
               Petitioner did not ask Mr. Ellison detailed questions about            
          the Hoyt partnerships--especially before they were contacted by             
          the Internal Revenue Service (IRS) about this investment and the            
          deductions associated with it.  Mr. Ellison’s responses to                  
          petitioner’s questions usually were along the lines of:  “Hoyt              
          has it under control”, “Hoyt is dealing with it”, or “Don’t worry           
          about it”.                                                                  
               Apart from the Hoyt partnerships, petitioner and Mr. Ellison           
          did not have any investments at the time they invested in the               
          Hoyt partnerships.                                                          
          Documents From the Hoyt Organization                                        
               Promotional materials and correspondence, including bills,             
          from the Hoyt organization were mailed (i.e., addressed) to                 


               3  Petitioner and Mr. Ellison invested in several other Hoyt           
          partnerships subsequent to the years in issue.                              





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