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or had reason to know of the item giving rise to the deficiency,
and (3) petitioner will not suffer economic hardship. Id.
Petitioner claims: She did not want to stay in the Hoyt
partnerships, but Mr. Ellison did; Mr. Ellison played the
dominant role in handling the financial affairs of their family;
and she did not have a choice not to sign the Hoyt documents or
her tax returns and that she had to do what Mr. Ellison wanted.
Petitioner left the final decision to invest in the Hoyt
partnerships to Mr. Ellison--essentially, petitioner acquiesced
or agreed to go along with Mr. Ellison’s wishes. Additionally,
petitioner and Mr. Ellison testified that Mr. Ellison did not
threaten or abuse petitioner and that he did not force petitioner
to invest in the Hoyt partnerships.
Petitioner also notes that Mr. Ellison opened all the mail
from the Hoyt organization and the IRS.
Mr. Ellison testified that he talked to petitioner about the
mail but that she was not interested. Mr. Ellison also testified
that petitioner could have understood the mail if she had read
it. Petitioner testified that she occasionally read documents
from the Hoyt organization or the IRS if Mr. Ellison left them
out. Petitioner also testified that she could have looked at the
mail and Mr. Ellison’s files regarding the Hoyt partnerships if
she had wanted.
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