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$12,500 in cash, and executing a promissory note for the
remainder, which note was paid by petitioner a year later.7
Prior to investing in Series 162, petitioner received an offering
memorandum and a brochure that summarized the offering.
Petitioner did not study these documents prior to his investment,
because, as an independent sales representative, he had studied
similar documents for other 1983 Barrister partnerships "with a
fine-toothed comb" and found that all of the partnerships were
"cookie cutter", i.e., basically the same. Furthermore, the
specific book properties purchased by Series 162 were not of
importance to petitioner.
For tax years 1983 and 1984, Series 162 reported partnership
losses of $210,789 and $285,234, and investment tax credits of
$4,593,000 and $1,770,000, respectively. On their 1983 and 1984
Federal income tax returns (returns), petitioners claimed their
4.8781 percent distributive share of these losses and investment
tax credits from Series 162. More specifically, petitioners
claimed partnership losses of $10,283 and $15,757 and investment
tax credits of $10,447 and $6,907 for 1983 and 1984,
respectively. In addition, petitioners claimed a tentative
7
The private placement memorandum (offering memorandum) of
Series 162, dated Dec. 19, 1983, indicates that the limited
partnership interests in Series 162 would be offered in 10 units
of $50,000 each, for a total of $500,000 to the partnership.
Although the record is not clear, petitioner apparently purchased
a half-unit, since his limited partnership interest cost $25,000.
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