- 9 - and Roberts were general partners together in other investments and maintained an office together in New York City. During 1981 Roberts served as second vice chairman of the Mountain Ridge State Bank (Mountain Ridge) in West Orange, New Jersey. As general partner, Roberts was personally responsible for the full amount due on the Northeast partnership lease. Petitioner contacted Roberts to discuss the Northeast transaction. Petitioner was provided a copy of Roberts' individual financial statement dated August 20, 1981. The financial statement showed a net worth for Roberts in the amount of $3,830,000. Petitioner asked his banker, Joseph Dowding (Dowding), to run a background check on Roberts and Mountain Ridge. Dowding reported that Mountain Ridge was a small bank and that its president had told him that Roberts had a fine business reputation. Also, a financial statement for Mountain Ridge was forwarded to petitioner. Petitioner was provided a copy of the offering memorandum for Northeast. The offering memorandum summarized the Northeast transaction and detailed the tax risk factors, business risk factors, and the business of the partnership, inter alia. The offering memorandum unambiguously disclosed that both Grant and Roberts were promoters of Northeast. Appendices to the memorandum include reports of F & G's evaluators, Stanley M. Ulanoff and Samuel Z. Burstein, and a draft letter of counsel regarding the tax risks associated with Northeast. PetitionerPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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