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6015(c) and (f)); Rowe v. Commissioner, supra; Buchine v.
Commissioner, supra.
In Bartak v. Commissioner, supra, Ellison v. Commissioner,
supra, and Doyel v. Commissioner, supra, the electing spouses
each agreed to invest in the investments which gave rise to the
erroneous items and did so jointly with their spouses by using
funds from joint bank accounts. Further, the electing spouses
considered the investments to be their own, as well as their
husbands’, and were denied relief because the erroneous items
were not entirely attributable to their husbands.
Similarly, in Abelein v. Commissioner, supra, and Capehart
v. Commissioner, supra, the electing spouses not only used funds
from joint accounts to invest, but also met and toured with
persons associated with the business activities, contacted them
on occasion, and received and read materials relating to them.
In contrast, in McKnight v. Commissioner, supra, Rowe v.
Commissioner, supra, and Buchine v. Commissioner, supra, because
they did not participate in the business activity, the electing
spouses were granted relief despite being named as shareholders or
partners. In Rowe the electing spouse did not make or participate
in any decision relating to the activity, did not sign any checks
relating to the activity, and was not otherwise involved in the
activity. In Buchine, the electing spouse’s name appeared as
shareholder and partner, but she had no knowledge of being named on
the Schedule K-1, and she only attended one promotional meeting.
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