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p. Due to the complexity of Jay Hoyt’s fraud, it was
impossible for either Petitioner or Mr. Bulger to
discover the true nature of the transactions.
q. Mr. Bulger and all other Hoyt investors were
deceived by Jay Hoyt as to the nature of their
investment and were ultimately determined by a
court of law to be victims of his elaborate fraud.
* * * * * * *
nn. Petitioner had no actual knowledge of the factual
circumstances that made the tax items unallowable
as a deduction.
On May 1, 2003, we filed respondent’s answer, in which he
denied each of petitioner’s allegations of error. Respondent
also denied petitioner’s representation that Mr. Bulger had died
and the representations in subparagraphs o., q., and nn. on the
basis of lack of knowledge or information. Respondent denied the
representation in subparagraph p. without qualification.
On February 23, 2004, this case was called for hearing
during the Court’s Seattle, Washington, trial session. The
parties reported that they believed they had reached a basis for
settlement, and the case was scheduled for recall on March 2,
2004. At the recall, petitioner stated that she wanted to verify
computational adjustments made by respondent and that the issue
of penalties had not been settled. On March 3, 2004, the parties
reported they were in agreement on the substantive issues in the
case but still disputed the computational adjustments. We
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