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In processing petitioner’s claim, the agent assigned to
petitioner’s case requested Hoyt partnerships related information
regarding petitioner and Mr. Ellison from Revenue Agent Deborah
Ritchie.6 Ms. Ritchie provided the employees reviewing
petitioner’s claim with a computer printout for Hoyt partnerships
taxable years related to petitioner and Mr. Ellison, copies of
Schedules K-1 issued to petitioner and Mr. Ellison from the Hoyt
partnerships, copies of checks signed by petitioner or Mr.
Ellison made payable to Hoyt partnerships, and Hoyt partnerships
documents signed by petitioner and Mr. Ellison.
On November 6, 2000, respondent mailed Mr. Ellison a letter
notifying him of petitioner’s request for relief from joint and
several liability.
On August 9, 2001, Ms. Halbert prepared a written evaluation
of petitioner’s claim. Ms. Halbert concluded that petitioner was
not entitled to section 6015(b) relief because petitioner knew of
the Hoyt partnerships and owned the item that gave rise to the
deficiency (i.e., the Hoyt partnerships). Ms. Halbert concluded
that no factor favored granting section 6015(f) relief and the
following factors weighed against granting section 6015(f)
relief: (1) Lack of economic hardship, (2) the liability was not
6 Ms. Ritchie worked on the “Hoyt audit team” and the “Hoyt
tax shelter project”. The Hoyt tax shelter project examined Hoyt
partnerships. Ms. Ritchie assisted District Counsel in preparing
Hoyt partnerships cases for trial.
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Last modified: May 25, 2011