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Petitioner subscribed to purchase one-half of a limited
partnership unit ($50,000) in EI. Petitioner could not recall if
he had borrowed the funds to invest in EI.
Through a teammate on the Chicago Bears professional
football team, petitioner met Efron at a cocktail party. He
learned of EI and the Clearwater transaction from Efron.
Efron was the general partner of EI. In addition, Efron
owned limited partnership interests in EI through Efron and Efron
Real Estate, a partnership owned by Efron and his wife, and AMBI
Real Estate, a partnership owned by Efron and his sister. EI was
the first partnership for which Efron served as a general
partner. Efron organized EI so that he could earn legal fees and
fees for managing the partnership. He received compensation and
fees as the general partner of EI and as a 50-percent shareholder
of MFA. Efron learned of the Clearwater transaction from Gordon.
In 1981 Gordon was counsel to EI, to Efron as the general
partner of EI, to Efron personally, and to MFA. He and Efron
have known each other since meeting at the University of Michigan
in 1955. In the early 1960's Efron and Gordon began investing
together in the stock market, real estate, business loans, and
other investments. Gordon is an attorney who holds a master's
degree in business administration and at one time was employed by
the Internal Revenue Service. Prior to the date of the
Clearwater private placement offering, Gordon had experience
involving the evaluation of tax shelters. Gordon was paid a fee
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