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told petitioner, and petitioner believed, that because they were
married they had to file joint tax returns. Glenn further told
petitioner that, because he was involved in the Hoyt
partnerships, she was required to sign the documents attached to
the returns relating to the Hoyt partnerships. Relying on Glenn,
petitioner signed the tax returns and attached materials, despite
having not read the materials. Petitioner did not read the
materials attached to the return because she felt she did not
know enough to understand them.
Each year, petitioner objected to signing the tax returns
reflecting the tax benefits relating to the Hoyt partnerships,
and petitioner asked Glenn to get out of the Hoyt partnership
investments. Petitioner reluctantly signed the tax returns and
attached documents only after Glenn reassured petitioner that tax
professionals had prepared them and that she was required to
sign.
During the years in issue, petitioner’s standard of living
remained constant. There were no lavish expenditures of any kind
that benefited petitioner, and petitioner did not receive any
benefit from the tax refunds and the tax reductions based on the
Hoyt partnerships because the tax refunds were deposited into
Glenn’s separate accounts and then contributed by Glenn back to
the partnerships.
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Last modified: November 10, 2007